875 F.2d 319
Unpublished Disposition
NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel.
Susan G. VAN SICKLE; Tom R. Van Sickle, Petitioners-Appellants,
v.
COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.
No. 88-7254.
United States Court of Appeals, Ninth Circuit.
Argued and Submitted May 8, 1989.
Decided May 19, 1989.
Before SNEED, HUG and SCHROEDER, Circuit Judges.
MEMORANDUM*
We affirm for the reasons stated by the tax court in its memorandum decision. The tax court's finding of fact that SIAA No. 3 held the subject property primarily for sale to customers in the ordinary course of business at the time of the relevant sales is not clearly erroneous. See McManus v. Commissioner, 583 F.2d 443, 446 (9th Cir.1978), cert. denied, 440 U.S. 959 (1979).
AFFIRMED.
This disposition is not appropriate for publication and may not be cited to or by the courts of this circuit except as provided by 9th Cir.R. 36-3