Cir

NOT FOR PUBLICATION FILED

FEB 25 2022

UNITED STATES COURT OF APPEALS

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

GEORGE J. SMITH; SHEILA ANN No. 20-70698

SMITH,

Tax Ct. No. 6105-16 Petitioners-Appellants,

v. MEMORANDUM*

COMMISSIONER OF INTERNAL

REVENUE,

Respondent-Appellee.

Appeal from a Decision of the United States Tax Court

Submitted February 15, 2022**

Before: FERNANDEZ, TASHIMA, and FRIEDLAND, Circuit Judges.

George J. and Sheila Ann Smith appeal pro se from the Tax Court’s

decision, following a bench trial, upholding the determinations of deficiency,

penalties, and an addition by the Commissioner of Internal Revenue regarding their

federal income taxes for the 2013 and 2014 tax years. We have jurisdiction under

* 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). 26 U.S.C. § 7482(a)(1). We review de novo the Tax Court’s legal conclusions and

for clear…