Cir

NOT FOR PUBLICATION FILED

UNITED STATES COURT OF APPEALS APR 1 2024

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

ESTATE OF MARY P. BOLLES, No. 22-70192 Deceased, John T. Bolles, Executor, Tax Ct. No. 4803-15 Petitioner-Appellant,

v. MEMORANDUM*

COMMISSIONER OF INTERNAL

REVENUE,

Respondent-Appellee.

Appeal from a Decision of the United States Tax Court

Submitted March 28, 2024** San Francisco, California

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

The Estate of Mary P. Bolles (“the Estate”) appeals from the Tax Court’s

orders finding an estate tax deficiency and declining to award administrative or

litigation costs. We have jurisdiction under 26 U.S.C. § 7482(a)(1). We review the

* 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). Tax Court’s determination of questions of fact for clear error and its conclusions of

law de…