Cir

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS JUL 13 2022

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

AARON G. FILLER, No. 21-71080

Petitioner-Appellant, Tax Ct. No. 23581-17

v.

MEMORANDUM*

COMMISSIONER OF INTERNAL

REVENUE,

Respondent-Appellee.

Appeal from a Decision of the United States Tax Court

Argued and Submitted June 15, 2022 Pasadena, California

Before: RAWLINSON and CHRISTEN, Circuit Judges, and BENNETT,** District Judge.

This case features an appeal from a Tax Court decision upholding a deficiency

and an accuracy-related penalty against Appellant Aaron Filler (“Dr. Filler”). Dr.

Filler is a licensed attorney and neurosurgeon who contributed to the development

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The Honorable Richard D. Bennett, United States Senior District Judge for the District of Maryland, sitting by designation. of Diffusion Tensor Imaging (“DTI”), a magnetic resonance imaging technique that

allows doctors to visualize nerve tissue in the…