Cir

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS SEP 19 2024

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

GREGORY JOSEPH PODLUCKY; No. 22-70169

KARLA S. PODLUCKY,

Tax Ct. No. 453-17 Petitioners-Appellants,

v. MEMORANDUM*

COMMISSIONER OF INTERNAL

REVENUE,

Respondent-Appellee.

Appeal from a Decision of the United States Tax Court

Submitted September 19, 2024**

Before: O’SCANNLAIN, KLEINFELD, and SILVERMAN, Circuit Judges.

Plaintiffs-appellants Gregory Joseph Podlucky (“Greg”) and Karla S.

Podlucky (“Karla”) (collectively, “Taxpayers”), appeal pro se the Tax Court’s

judgment on their petition for redetermination of federal income tax deficiencies

for 2003-2006. We have jurisdiction under 26 U.S.C. § 7483. We review de novo

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). the Tax Court’s legal conclusions and for clear error its…