Opinion
Argued and Submitted May 13, 2003.
NOT FOR PUBLICATION. (See Federal Rule of Appellate Procedure Rule 36-3)
Appeal from a Decision of the Internal Revenue Service.
Before CANBY, KLEINFELD, and RAWLINSON, Circuit Judges.
This disposition is not appropriate for publication and may not be cited to or by the courts of this circuit except as provided by Ninth Circuit Rule 36-3.
The tax court did not clearly err when it determined that the transfer of real property from Appellant George Tsakopoulos to his brother was not an abandonment of the property. See A.J. Indus., Inc. v. United States, 503 F.2d 660, 670-71 (9th Cir.1974).
AFFIRMED.