Cir

NOT FOR PUBLICATION

UNITED STATES COURT OF APPEALS

FILED

FOR THE NINTH CIRCUIT

OCT 8 2021

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

RAYMOND CHICO; RUBY CHICO, No. 20-71017

Petitioners-Appellants, Tax Ct. No. 22264-

v.

MEMORANDUM*

COMMISSIONER OF INTERNAL

REVENUE,

Respondent-Appellee.

Appeal from a Decision of the United States Tax Court

Submitted October 6, 2021** San Francisco, California

Before: THOMAS, Chief Judge, and HAWKINS and FRIEDLAND, Circuit Judges.

Raymond and Ruby Chico appeal the Tax Court’s imposition of a fraud

penalty for their 2010 through 2012 federal income tax returns. We have

jurisdiction under 26 U.S.C. § 7482(a)(1), and 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). We review the Tax Court’s imposition of a fraud penalty for clear error, see

Bradford v. Comm’r, 796 F.2d 303, 307 (9th Cir. 1986), and we apply clear error

review to Tax Court decisions based on a stipulated record, even when…