Citation Codes Equivalent Citations citation codes Docket Number No. 06-75806. Attorney(S) Khen T. Huynh, San Diego, CA, pro se. Robert R. Di Trolio, Washington, DC, Donald L. Korb, Acting Chief Counsel Internal Revenue Service, Washington, DC, Eileen J. O'Connor, Esq., Bethany B. Hauser, Esq., U.S. Department of Justice Tax Division/Appellate Section, Washington, DC, for Respondent-Appellee. Judges Susan Graber Raymond C. Fisher Marsha Siegel Berzon Acts Internal Revenue Code — Procedure And Administration — Information And Returns — Returns And Records — Tax Returns Or Statements — Income Tax Returns — Relief From Joint And Several Liability On Joint Return Internal Revenue Code — Procedure And Administration — Judicial Proceedings — Court Review Of Tax Court Decisions — Courts Of Review See more information ... Smart Summary Please sign up to generate summary. Khen T. HUYNH, Petitioner — Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent — Appellee. MEMORANDUM This disposition is not appropriate for publication and is not precedent except as provided by 9th Cir. R. 36-3. Khen T. Huynh appeals pro se from the Tax Court's decision upholding the denial of relief under 26 U.S.C. § 6015 from joint liability with her husband for tax deficiencies in 1996 and 1997. We have jurisdiction pursuant to 26 U.S.C. § 7482(a)(1). We review for clear error the Tax Court's factual findings, including the determination that Huynh is not entitled to innocent spouse relief under § 6015. See Guth v. Comm'r, 897 F.2d 441, 443 (9th Cir. 1990) (reviewing claim for relief under predecessor statute). We affirm. The Tax Court did not clearly err in finding that Huynh meaningfully participated in prior proceedings concerning her tax liability for 1996 and 1997 given that she prepared the tax returns, signed documents, participated in pretrial preparations and settlement negotiations, and testified on the substance of the tax matters at the prior trial. See 26 U.S.C. § 6015(g)(2). AFFIRMED.