Estate of Howard v. Moore v. Cir

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS NOV 8 2021

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

ESTATE OF HOWARD V. MOORE, No. 20-73013 Deceased; et al., Tax Ct. Nos. 21209-09 Petitioners-Appellants, 22082-

v.

MEMORANDUM*

COMMISSIONER OF INTERNAL

REVENUE,

Respondent-Appellee.

Appeal from a Decision of the United States Tax Court

Argued and Submitted October 18, 2021 San Francisco, California

Before: WATFORD and HURWITZ, Circuit Judges, and BAKER,** International Trade Judge.

Prior to Howard V. Moore’s death, the Howard V. Moore Family Limited

Partnership sold Moore Farms to a third party. The Howard V. Moore Living Trust

then sold its interest in the Partnership to the Howard V. Moore Irrevocable Trust

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The Honorable M. Miller Baker, Judge for the United States Court of International Trade, sitting by designation. No. 1. After Moore’s death, the Partnership transferred the proceeds from the sale

of the Farm to…