MEMORANDUM**

Ronald and Annette Talmage appeal a Tax Court decision in favor of the Commissioner. We have jurisdiction under 26 U.S.C. § 7482. Having reviewed the tax court’s findings of fact for clear error, LOAD, Inc. v. Comm’r, 559 F.3d 909, 911 (9th Cir. 2009), we affirm for the reasons stated by Judge Harry Haines in T.C. Memo. 2008-34 (Feb. 19, 2008).

AFFIRMED.