NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS MAY 24 2018 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT JEANNE E. MUNSON, No. 17-72314 Petitioner-Appellant, Tax Ct. No. 11586-16L v. MEMORANDUM* COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

TROY J. MUNSON, No. 17-72315 Petitioner-Appellant, Tax Ct. No. 10544-16L v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

Appeals from Decisions of the United States Tax Court Submitted May 15, 2018** * This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes these cases are suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2).

Before: SILVERMAN, BEA, and WATFORD, Circuit Judges.

In these consolidated appeals, Jeanne E. Munson and Troy J. Munson appeal pro se from the Tax Court’s decisions upholding federal income tax liability. We have jurisdiction under 26 U.S.C. § 7482(a)(1). We affirm.

The Munsons have waived their challenge to the Tax Court’s determinations by failing to address in their consolidated opening brief how the Tax Court erred in reaching its conclusions. See Smith v. Marsh, 194 F.3d 1045, 1052 (9th Cir. 1999) (“[O]n appeal, arguments not raised by a party in its opening brief are deemed waived.”); Greenwood v. FAA, 28 F.3d 971, 977 (9th Cir. 1994) (“We will not manufacture arguments for an appellant, and a bare assertion does not preserve a claim[.]”).

Because we conclude that the Munsons waived their challenge as to the substance of the underlying collection actions, we do not consider the merits of the Munsons’ arguments regarding the Tax Court employing summary judgment procedures to review the Commissioner’s determinations under § 6330(d).

17-72314: AFFIRMED.

17-72315: AFFIRMED.

2 17-72314