Cir

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS OCT 23 2024

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

GEORGE J. SMITH; SHEILA ANN No. 22-70200

SMITH,

Tax Ct. No. 10759-20 Petitioners-Appellants,

v. MEMORANDUM*

COMMISSIONER OF INTERNAL

REVENUE,

Respondent-Appellee.

Appeal from a Decision of the United States Tax Court

Submitted October 16, 2024**

Before: SILVERMAN, R. NELSON, and MILLER, Circuit Judges.

George J. Smith and Sheila Ann Smith appeal pro se from the Tax Court’s

summary judgment upholding the Commissioner of Internal Revenue’s

determination of deficiency for tax year 2016. We have jurisdiction under

U.S.C. § 7482(a)(1). We review de novo. Sollberger v. Comm’r, 691 F.3d 1119,

* 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). 1123 (9th Cir. 2012). We affirm.

The Tax Court properly granted summary judgment for…