Cir

MEMORANDUM

Russell Van Camp and Teresa Van Camp appeal the Tax Court’s decision to deny the Van Camps’ request to remand their case to the IRS Office of Appeals. We have jurisdiction under 26 U.S.C. § 7482 (a)(1).

“We review decisions of the Tax Court under the same standards as civil bench trials in the district court.” Milenbach v. C.I.R., 318 F.3d 924 , 930 (9th Cir.2003). The Tax Court’s “conclusions of law are reviewed de novo, and questions of fact are reviewed' for clear error.” Id. The Tax Court’s factual findings are clearly erroneous if they are “(1) illogical, (2) implausible, or (3) without support in inferences that may be drawn from the facts in the record.” Meruelo v. C.I.R., 691 F.3d 1108, 1114 (9th Cir.2012) (quoting United States v. Hinkson, 585 F.3d 1247, 1262 (9th Cir.2009) (en banc)).

The Van Camps contend Russell Van Camp’s disbarment from the Washington State Bar was a changed circumstance affecting the Van Camps’ finances. And, as a result, the Tax Court should have remanded the Van Camps’ case back to the IRS Office of Appeals to reevaluate then-ability to make installment payments on their unpaid tax liabilities. The Tax Court found there were no…