Cir

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS MAY 23 2025

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

JOSEPH WILLIAM SHERMAN, No. 23-70161

Petitioner-Appellant, Tax Ct. No. 22276-

v.

MEMORANDUM*

COMMISSIONER OF INTERNAL

REVENUE,

Respondent-Appellee.

Appeal from a Decision of the United States Tax Court

Submitted May 21, 2025**

Before: SILVERMAN, LEE, and VANDYKE, Circuit Judges.

Joseph William Sherman appeals pro se from the Tax Court’s order,

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

determination of an income tax deficiency and imposition of penalties against him

for tax year 2015. We have jurisdiction under 26 U.S.C. § 7482(a)(1). We review

* 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). de novo the Tax Court’s legal conclusions and for clear error its factual findings.

Cooper v. Comm’r, 877 F.3d 1086, 1090 (9th…