NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS DEC 23 2025 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT NATARAJAN PALANIAPPAN; SATYA No. 24-2502 SREE DANDAMUDI, D.C. No. 2:22-cv-01685-DLR Plaintiffs - Appellants, MEMORANDUM* v. UNITED STATES OF AMERICA, Defendant - Appellee.

Appeal from the United States District Court for the District of Arizona Douglas L. Rayes, District Judge, Presiding Submitted December 17, 2025** Before: PAEZ, CHRISTEN, and KOH, Circuit Judges.

Natarajan Palaniappan and Satya Sree Dandamudi appeal pro se from the district court’s judgment on the pleadings in their action seeking a tax refund from the IRS for tax year 2016. We have jurisdiction under 28 U.S.C. § 1291. We

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). review de novo. Fleming v. Pickard, 581 F.3d 922, 925 (9th Cir. 2009). We affirm.

The district court properly granted judgment on the pleadings on the basis of issue preclusion because the issues of whether Palaniappan participated in the 409A plan and whether the lump sum distribution was subject to income tax withholding were actually litigated and decided in a prior bankruptcy proceeding.

See Janjua v. Neufeld, 933 F.3d 1061, 1065 (9th Cir. 2019) (setting forth requirements for issue preclusion under federal law).

We do not consider matters not specifically and distinctly raised and argued in the opening brief, or arguments and allegations raised for the first time on appeal. See Padgett v. Wright, 587 F.3d 983, 985 n.2 (9th Cir. 2009).

AFFIRMED.

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