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Ninth Circuit Affirms Tax Court; Couple Is Liable for Deficiency

JUL. 16, 2020

Singh, Raghvendra et ux. v. Commissioner

DATED JUL. 16, 2020
DOCUMENT ATTRIBUTES
  • Case Name
    Raghvendra Singh et ux. v. Commissioner
  • Court
    United States Court of Appeals for the Ninth Circuit
  • Docket
    No. 18-72695
  • Judge
    Per Curiam
  • Parallel Citation
    812 Fed. Appx. 579
    2020-2 U.S. Tax Cas. (CCH) P50,151
    2020 WL 4013989
  • Subject Area/Tax Topics
  • Jurisdictions
  • Tax Analysts Document Number
    2020-27409
  • Tax Analysts Electronic Citation
    2020 TNTF 138-40

Singh, Raghvendra et ux. v. Commissioner

RAGHVENDRA SINGH; KIRAN RAWAT,
Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent-Appellee.

NOT FOR PUBLICATION

UNITED STATES COURT OF APPEALS
FOR THE NINTH CIRCUIT

Appeal from a Decision of the
United States Tax Court

Submitted July 14, 2020*

MEMORANDUM**

Before: CANBY, FRIEDLAND, and R. NELSON, Circuit Judges.

Raghvendra Singh and Kiran Rawat appeal pro se from the Tax Court's decision, following a bench trial, upholding the determination of deficiency by the Commissioner of Internal Revenue regarding their federal income taxes for the 2012 tax year. We have jurisdiction under 26 U.S.C. § 7482(a)(1). We review de novo the Tax Court's legal conclusions, and for clear error its factual determinations. Hongsermeier v. Comm'r, 621 F.3d 890, 899 (9th Cir. 2010). We affirm.

The Tax Court did not clearly err in finding that Singh and Rawat were not entitled to various alleged business, mortgage interest, and real estate deductions because they failed to offer evidence that clearly showed a right to the claimed deductions. See Sparkman v. Comm'r, 509 F.3d 1149, 1159 (9th Cir. 2007) (noting that the taxpayer bears the burden of “clearly showing” the right to the claimed deduction); Bradford v. Comm'r, 796 F.2d 303, 306 (9th Cir. 1986) (taxpayers are required to substantiate the amounts expended on cost of goods).

We reject as meritless Singh and Rawat's various contentions, including that their due process rights were violated, that the IRS was required to provide them a trial transcript, that the trial judge should have entered default judgment in their favor, and that the IRS committed fraud.

We do not consider arguments and allegations raised for the first time on appeal. See Padgett v. Wright, 587 F.3d 983, 985 n.2 (9th Cir. 2009).

AFFIRMED.

FOOTNOTES

*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).

END FOOTNOTES

DOCUMENT ATTRIBUTES
  • Case Name
    Raghvendra Singh et ux. v. Commissioner
  • Court
    United States Court of Appeals for the Ninth Circuit
  • Docket
    No. 18-72695
  • Judge
    Per Curiam
  • Parallel Citation
    812 Fed. Appx. 579
    2020-2 U.S. Tax Cas. (CCH) P50,151
    2020 WL 4013989
  • Subject Area/Tax Topics
  • Jurisdictions
  • Tax Analysts Document Number
    2020-27409
  • Tax Analysts Electronic Citation
    2020 TNTF 138-40
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