Michael Brown v. Cir

FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT MICHAEL D. BROWN, No. 23-70009 Petitioner-Appellant, Tax Ct. No. 11519-20L v. COMMISSIONER OF INTERNAL OPINION REVENUE, Respondent-Appellee. Appeal from a Decision of the United States Tax Court Argued and Submitted December 7, 2023 Pasadena, California Filed August 29, 2024 Before: Kim McLane Wardlaw, Kenneth K. Lee, and Patrick J. Bumatay, Circuit Judges. Opinion by Judge Wardlaw; Concurrence by Judge Lee; Dissent by Judge Bumatay 2 BROWN V. CIR SUMMARY * Tax The panel affirmed the Tax Court’s judgment sustaining a notice…