Nathan T. Olpin v. Commissioner of Internal Revenue

McKAY, Circuit Judge.

Nathan T. Olpin appeals a United States Tax Court order granting summary judgment in favor of the Commissioner of Internal Revenue and denying his motion for summary judgment. Our jurisdiction arises under 26 U.S.C. § 7482(a)(1).

I. Standard of Review

We review Tax Court decisions “in the same manner and to the same extent as decisions of the district courts in civil actions tried without a jury.” § 7482(a)(1). The relevant facts are undisputed, and we review the Tax Court’s grant and denial of summary judgment de novo. TeleCommunications, Inc. v. Comm’r, 104 F.3d 1229,…