
    Philip A. DUGGAN, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
    No. 14-71645
    United States Court of Appeals, Ninth Circuit.
    Submitted January 18, 2017 
    
    Filed January 26, 2017
    Philip A. Duggan, Pro Se
    Julie Ciamporcero Avetta, Attorney, Francesca Ugolini, Attorney, DOJ—U.S. Department of Justice, Tax Division/Appellate Section, Washington, DC, William J. Wilkins, Chief Counsel, Internal Revenue Service, Washington, DC, for Respondent-Appellee
    Before: TROTT, TASHIMA, and CALLAHAN, Circuit Judges.
    
      
       The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2).
    
   MEMORANDUM

Philip A. Duggan appeals pro se from the Tax Court’s decision, after a bench trial, upholding the Commissioner of the Internal Revenue’s determination of income tax deficiencies and penalties for tax year 2008. 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 findings. Hardy v. Comm’r, 181 F.3d 1002, 1004 (9th Cir. 1999). We affirm.

The Tax Court, properly upheld the Commissioner’s deficiency determination because the Commissioner presented “some substantive evidence” that Duggan failed to report income and Duggan did not submit any relevant evidence “showing that the deficiency was arbitrary or erroneous.” Id. at 1004-05.

The Tax Court properly upheld the Commissioner’s additions to taxes for Dug-gan’s failure to file a required tax return in a timely manner and for his failure to pay estimated taxes for 2008. See 26 U.S.C. §§ 6651(a)(1), 6654(a).

We reject as meritless Duggan’s arguments regarding the Commissioner’s attorneys having “unclean hands.”

AFFIRMED. 
      
       This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3.
     