Unpublished Disposition, 875 F.2d 319 (9th Cir. 1989)

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U.S. Court of Appeals for the Ninth Circuit - 875 F.2d 319 (9th Cir. 1989)

Susan G. VAN SICKLE; Tom R. Van Sickle, Petitioners-Appellants,v.COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.

No. 88-7254.

United States Court of Appeals, Ninth Circuit.

Argued and Submitted May 8, 1989.Decided May 19, 1989.

Before SNEED, HUG and SCHROEDER, Circuit Judges.


MEMORANDUM* 

We affirm for the reasons stated by the tax court in its memorandum decision. The tax court's finding of fact that SIAA No. 3 held the subject property primarily for sale to customers in the ordinary course of business at the time of the relevant sales is not clearly erroneous. See McManus v. Commissioner, 583 F.2d 443, 446 (9th Cir. 1978), cert. denied, 440 U.S. 959 (1979).

AFFIRMED.

 *

This disposition is not appropriate for publication and may not be cited to or by the courts of this circuit except as provided by 9th Cir.R. 36-3