SEAVIEW TRADING, LLC, AGK INVE V. CIR

Opinion

FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS NOV 10 2022 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

SEAVIEW TRADING, LLC, AGK No. 20-72416 INVESTMENTS, LLC, TAX MATTERS PARTNER, Tax Ct. No. 1837-11

Petitioner-Appellant, ORDER v.

COMMISSIONER OF INTERNAL REVENUE,

Respondent-Appellee.

MURGUIA, Chief Judge:

Upon the vote of a majority of nonrecused active judges, it is ordered that

this case be reheard en banc pursuant to Federal Rule of Appellate Procedure 35(a)

and Circuit Rule 35-3. The three-judge panel opinion is vacated.