Load

FOR PUBLICATION

UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

LOAD, INC.; COAD, INC., 

Petitioners, No. 07-72564 v.  D.C. No.

CIR-1 : 7287-

COMMISSIONER OF INTERNAL

REVENUE, OPINION

Respondent.  Appeal from a Decision of the United States Tax Court Stephen J. Swift, Judge, Presiding

Argued and Submitted January 14, 2009—San Francisco, California

Filed February 2, 2009

Before: Myron H. Bright,* Procter Hug, Jr., and Stephen Reinhardt, Circuit Judges.

Per Curiam Opinion

*The Honorable Myron H. Bright, Senior United States Circuit Judge for the Eighth Circuit, sitting by designation.

1173 1174 LOAD, INC. v. CIR

COUNSEL

John F. Daniels, Janice Procter-Murphy, Alexander Arpad, Phoenix, Arizona, for the petitioners.

Richard T. Morrison, Acting Assistant Attorney General, Teresa E. McLaughlin, Kathleen E. Lyon, Washington, D.C., for the respondent.

OPINION

PER CURIAM:

Appellants LOAD, Inc. and COAD, Inc.1 challenge the Tax Court’s determination of a federal income tax deficiency for the tax year ending September 30, 2000. The Tax Court held that certain of ADI’s…