Orian E. Wright and Mary M. Wright, v Commissioner of Internal Revenue

891 F.2d 297 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Orian E. WRIGHT and Mary M. Wright, Petitioners/Appellants, v COMMISSIONER OF INTERNAL REVENUE, Respondent/Appellee. No. 88-7449. United States Court of Appeals, Ninth Circuit. Submitted Oct. 26, 1989. * Decided Dec. 6, 1989. Before ALARCON, O'SCANNLAIN, and LEAVY, Circuit Judges. 1 MEMORANDUM ** 2 Orian Wright and Mary Wright appeal pro se from a judgment of the United States Tax Court on the pleadings and an award of damages under 26 U.S.C. § 6673 . The Wrights set out multiple claims, alleging lack of constitutional and statutory authority for the Commissioner to issue notices of deficiency for their unreported wages. We affirm and impose sanctions. 3 We review decisions of the Tax Court on the same basis as decisions in civil bench trials in the United States District Courts. Mayors v. Commissioner, 785 F.2d 757, 759 (9th Cir.1986). A tax court's exercise of jurisdiction is reviewed de novo. Clapp v.…