The Ninth Circuit Court of Appeals today released an opinion in CIR v. POLONE, No. 04-72672, a tax appeal. The panel consisted of Jerome Farris and Sidney R. Thomas, Circuit Judges, and George Schiavelli, District Judge.

THOMAS, Circuit Judge:
This appeal presents the question of whether payments received after the effective date of amendments to 26 U.S.C. . . .

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