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OLPIN v. C.I.R.

No. 00-9003.

270 F.3d 1297 (2001)

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

United States Court of Appeals, Tenth Circuit.

November 5, 2001.

Attorney(s) appearing for the Case

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

Karen D. Utiger (Randolph Hutter and Ann B. Durney with her on the briefs), U.S. Department of Justice, Tax Division, Washington, D.C., for Respondent-Appellee.

Before KELLY and McKAY, Circuit Judges, and BROWN, District Judge.

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...

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