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BANAITIS v. C.I.R.

No. 02-70421.

340 F.3d 1074 (2003)

Sigitas BANAITIS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Ninth Circuit.

Filed August 27, 2003.

Attorney(s) appearing for the Case

Joseph Wetzel and Russell A. Sandor; Wetzel, DeFrang, & Sandor; and Philip N. Jones; Duffy Kekel LLP; Portland, Oregon; attorneys for the petitioner.

Eileen J. O'Connor, Richard Farber, and Kenneth Rosenberg, United States Department of Justice, Tax Division; Washington, D.C.; attorneys for the respondent.

Before: Robert R. BEEZER, Sidney R. THOMAS, and Richard R. CLIFTON, Circuit Judges.

Argued and Submitted February 14, 2003 — San Francisco, California.

OPINION

THOMAS, Circuit Judge.

Sigitas Banaitis appeals the United States Tax Court's entry of judgment in favor of the Commissioner of Internal Revenue regarding a $1,708,216 deficiency in Banaitis' 1995 income tax. We affirm in part and reverse in part.

I

From 1980 until late 1987, Sigitas Banaitis, an Oregon...

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