Filed: Mar. 09, 2020
Latest Update: Mar. 09, 2020
Summary: NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS MAR 9 2020 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT ALICIA M. FIEDZIUSZKO; SLAWOMIR No. 18-73342 J. FIEDZIUSZKO, Tax Ct. No. 15229-15 Petitioners-Appellants, v. MEMORANDUM* COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Appeal from a Decision of the United States Tax Court Submitted March 3, 2020** Before: MURGUIA, CHRISTEN, and BADE, Circuit Judges. Alicia Fiedziuszko and Slawomir Fiedziuszko appeal pro se
Summary: NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS MAR 9 2020 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT ALICIA M. FIEDZIUSZKO; SLAWOMIR No. 18-73342 J. FIEDZIUSZKO, Tax Ct. No. 15229-15 Petitioners-Appellants, v. MEMORANDUM* COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Appeal from a Decision of the United States Tax Court Submitted March 3, 2020** Before: MURGUIA, CHRISTEN, and BADE, Circuit Judges. Alicia Fiedziuszko and Slawomir Fiedziuszko appeal pro se ..
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NOT FOR PUBLICATION FILED
UNITED STATES COURT OF APPEALS MAR 9 2020
MOLLY C. DWYER, CLERK
U.S. COURT OF APPEALS
FOR THE NINTH CIRCUIT
ALICIA M. FIEDZIUSZKO; SLAWOMIR No. 18-73342
J. FIEDZIUSZKO,
Tax Ct. No. 15229-15
Petitioners-Appellants,
v. MEMORANDUM*
COMMISSIONER OF INTERNAL
REVENUE,
Respondent-Appellee.
Appeal from a Decision of the
United States Tax Court
Submitted March 3, 2020**
Before: MURGUIA, CHRISTEN, and BADE, Circuit Judges.
Alicia Fiedziuszko and Slawomir Fiedziuszko appeal pro se from the Tax
Court’s order finding deficiencies in their income tax for tax year 2012. We have
jurisdiction under 26 U.S.C. § 7482(a). We review for “clear error the Tax Court’s
factual determination that a taxpayer has failed to produce sufficient evidence to
*
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).
substantiate a deduction.” Sparkman v. Comm’r,
509 F.3d 1149, 1159 (9th Cir.
2007). We affirm.
The Tax Court did not clearly err in determining that the Fiedziuszkos failed
to produce sufficient evidence to demonstrate their entitlement to further
deductions for expenses related to business expenses, medical and dental expenses,
and noncash charitable contributions. See 26 U.S.C.A. §§ 170, 213(a), 274(d),
6001; 26 C.F.R. §§ 1.170A–1(c), 1.170A-13(b), 1.213-1(h), 1.6001-1(a);
Sparkman, 509 F.3d at 1159 (9th Cir. 2007) (taxpayer bears burden of clearly
showing right to claimed deduction).
AFFIRMED.
2 18-73342