Cir

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS DEC 10 2024

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

CHARLES KINNEY, No. 22-70265

Petitioner-Appellant, Tax Ct. No. 17664-

v.

MEMORANDUM*

COMMISSIONER OF INTERNAL

REVENUE,

Respondent-Appellee.

Appeal from a Decision of the United States Tax Court

Submitted December 10, 2024**

Before: BENNETT, BADE, and COLLINS, Circuit Judges.

Petitioner-Appellant Charles Kinney appeals pro se from the Tax Court’s

order, following a bench trial, upholding the Commissioner of Internal Revenue’s

determination of income tax deficiencies for tax year 2016. We have jurisdiction

under 26 U.S.C. § 7482(a)(1). We review the Tax Court’s legal conclusions de

novo and its factual findings for clear error. Cooper v. Comm’r, 877 F.3d 1086,

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes that this case is suitable for decision without oral argument. See FED. R. APP. P. 34(a)(2)(C). 1090 (9th Cir. 2017). We review for…