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OLPIN v. C.I.R.

No. 00-9003.

237 F.3d 1263 (2001)

Nathan T. OLPIN, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

January 25, 2001.

Attorney(s) appearing for the Case

Submitted on the briefs:

W. Kevin Jackson of Jensen, Duffin, Carman, Dibb & Jackson, Salt Lake City, Utah, for Petitioner-Appellant.

Randolph Hutter, Ann B. Durney, and Karen D. Utiger, U.S. Department of Justice, Tax Division-Appellate Division, Washington, DC, for Respondent-Appellee.

Before BALDOCK, ANDERSON, and HENRY, Circuit Judges.

BALDOCK, Circuit Judge.

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

We review Tax Court decisions "in the same manner and to the same extent as decisions of the district courts...

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