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TRICARICHI v. C.I.R.

No. 16-73418.

908 F.3d 588 (2018)

Michael A. TRICARICHI, Transferee, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed November 13, 2018.

Attorney(s) appearing for the Case

Michael J. Desmond (argued), Law Offices of Michael J. Desmond APC, Santa Barbara, California, for Petitioner-Appellant.

Clint A. Carpenter (argued), Francesca Ugolini , and Gilbert S. Rothenberg , Attorneys; David A. Hubbert , Acting Assistant Attorney General; Tax Division, United States Department of Justice, Washington, D.C.; for Respondent-Appellee.

Before: William A. Fletcher, Carlos T. Bea, and John B. Owens, Circuit Judges.

OPINION

Taxpayer Michael A. Tricarichi appeals from the tax court's decision on his petition challenging a notice of transferee liability regarding West Side Cellular, Inc.'s ("West Side") unpaid taxes. We have jurisdiction under 26 U.S.C. § 7482. In this opinion, we affirm the tax court's conclusion that Tricarichi...

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