Calvo v. Commissioner of Internal Revenue Service

JUDGMENT

This appeal was considered on the rec-' ord from the United States Tax Court and on the briefs filed by the parties. See Fed. R. App. P. 34(a)(2); D.C. Cir. Rule 34(3). It is

ORDERED AND ADJUDGED that the Tax Court’s orders of February 9, 2015 and March 2, 2015 be affirmed. On the record before it, the Tax Court properly determined Calvo’s requests for review of the Internal Revenue Service’s (“IRS”) denial of innocent-spouse relief under 26 U.S.C. § 6015 and his request for relief *768from the deficiency notice under 26 U.S.C. § 6213 were untimely. Calvo failed to show that the deficiency…