Cir

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS FEB 3 2022

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

LINDSEY JONES, No. 20-70013

Petitioner-Appellant, Tax Ct. No. 32168-15

v.

MEMORANDUM*

COMMISSIONER OF INTERNAL

REVENUE,

Respondent-Appellee.

Appeal from a Decision of the United States Tax Court

Argued and Submitted January 18, 2022 Honolulu, Hawaii

Before: O’SCANNLAIN, MILLER, and LEE, Circuit Judges.

Lindsey Jones appeals from the tax court’s decision denying relief from joint

and several liability for underpayments of her 2009 and 2010 income tax. We have

jurisdiction under 26 U.S.C. § 7482(a)(1), and we affirm.

1. The tax court did not err by concluding that Jones tacitly consented to

the filing of the 2010 joint return. See Slone v. Commissioner, 810 F.3d 599, 604

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. (9th Cir. 2015) (“We review a tax court’s factual determinations for clear error and

its application of legal standards de novo.”). A joint tax…