Cir

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS DEC 17 2021

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

WILLIAM A. GODDARD, No. 20-73023

Petitioner-Appellant, IRS Nos. 1143-05 1145-05 v. 1335-06 1504-

COMMISSIONER OF INTERNAL 20673-

REVENUE, 20674-

20675-09 Respondent-Appellee. 20676-09 20677-09 20678-

MEMORANDUM*

On Petition for Review of an Order of the United States Tax Court

Argued and Submitted December 7, 2021 San Francisco, California

Before: LUCERO,** IKUTA, and VANDYKE, Circuit Judges.

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The Honorable Carlos F. Lucero, United States Circuit Judge for the U.S. Court of Appeals for the Tenth Circuit, sitting by designation. William Goddard appeals from a Tax Court decision affirming the

Commissioner’s assessment of nearly $5 million in back taxes. On…