Cir

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS JUN 2 2022

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

DEBRA JEAN BLUM, No. 21-71113

Petitioner-Appellant, Tax Ct. No. 20020-

v.

COMMISSIONER OF INTERNAL AMENDED MEMORANDUM*

REVENUE,

Respondent-Appellee.

Appeal from a Decision of the United States Tax Court

Argued and Submitted March 8, 2022 Seattle, Washington

Before: NGUYEN, MILLER, and BUMATAY, Circuit Judges.

Debra Blum appeals from a Tax Court decision upholding the Internal

Revenue Service’s tax deficiency determination of $27,418.00. We review the Tax

Court’s interpretations of the Tax Code de novo, Meruelo v. Comm’r, 691 F.3d 1108,

1114 (9th Cir. 2012), and findings of fact for clear error, Boyd Gaming Corp. v.

Comm’r, 177 F.3d 1096, 1098 (9th Cir. 1999). We have jurisdiction under 26 U.S.C.

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. § 7482(a)(1) and affirm.

The Tax Court properly found that Blum’s legal malpractice…