
    George TSAKOPOULOS; Drousoula Tsakopoulos, Petitioners—Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent—Appellee.
    No. 02-70610.
    IRS No. 14050-98/1131-00.
    United States Court of Appeals, Ninth Circuit.
    Argued and Submitted May 13, 2003.
    Decided May 19, 2003.
    Before CANBY, KLEINFELD, and RAWLINSON, Circuit Judges.
   MEMORANDUM

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. 
      
       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.
     