Cir

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS JUL 21 2022

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

MOJDEH NAJLE-RAHIM, No. 20-72031

Petitioner-Appellant, Tax Ct. No. 15855-

v.

MEMORANDUM*

COMMISSIONER OF INTERNAL

REVENUE,

Respondent-Appellee.

Appeal from a Decision of the United States Tax Court

Submitted July 21, 2022**

Before: WALLACE, D.W. NELSON, and FERNANDEZ, Circuit Judges.

Dr. Mojdeh Najle-Rahim, proceeding pro se, appeals from the Tax Court’s

decision upholding the Commissioner’s determination of income tax deficiencies

and application of fraud penalties against Dr. Najle-Rahim and her husband,

Seyed-Jalil Ghadiri-Asli (collectively, “taxpayers”) for 2009, 2010, and 2011. We

* 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). have jurisdiction under 26 U.S.C. § 7482(a)(1). We review for clear error. Akland

v. Comm’r of Internal Revenue,…