Lewis

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS NOV 18 2025

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

GLEN LEWIS, No. 24-3828 Tax Ct. No. 22829-22L Petitioner - Appellant,

v. MEMORANDUM*

COMMISSIONER OF INTERNAL

REVENUE,

Respondent - Appellee.

Appeal from a Decision of the United States Tax Court

Submitted November 12, 2025**

Before: SCHROEDER, RAWLINSON, and NGUYEN, Circuit Judges.

Glen Lewis appeals pro se from the Tax Court’s summary judgment

sustaining the Commissioner of Internal Revenue’s rejection of Lewis’s offer in

compromise and acceptance of an installment agreement in lieu of levying Lewis’s

assets. We have jurisdiction under 26 U.S.C. § 7482(a)(1). 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). Sollberger v. Comm’r, 691 F.3d 1119, 1123 (9th Cir. 2012) (summary…