Cir

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS OCT 15 2025

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

EMILIO TORRES LUQUE; GABRIELA No. 23-70145

MEDINA,

Tax Ct. No. 14962-10 Petitioners-Appellants,

v. MEMORANDUM*

COMMISSIONER OF INTERNAL

REVENUE,

Respondent-Appellee.

Appeal from a Decision of the United States Tax Court

Submitted August 19, 2025**

Before: SILVERMAN, HURWITZ, and BADE, Circuit Judges.

Emilio Torres Luque and Gabriela Medina appeal pro se from the Tax

Court’s order denying their motion to vacate. We have jurisdiction under 26

U.S.C. § 7482(a)(1). We review for an abuse of discretion. Abatti v. Comm’r, 859

F.2d 115, 117 (9th Cir. 1988). We affirm.

* 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 did not abuse its discretion by denying petitioners’ motion to

vacate summary judgment because it…