Paul Befumo v. Commissioner Internal Revenue Service

968 F.2d 1220 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Paul BEFUMO, Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 91-70649. United States Court of Appeals, Ninth Circuit. Submitted July 8, 1992. * Decided July 13, 1992. Before POOLE, BEEZER and KOZINSKI, Circuit Judges. 1 MEMORANDUM ** 2 Paul Befumo appeals pro se the tax court's decision upholding the Commissioner of Internal Revenue Service's determination of deficiencies and additions to taxes for tax years 1985 and 1986. We have jurisdiction pursuant to 26 U.S.C. § 7482 (a). We review the tax court's conclusions of law de novo and its findings of fact for clear error. Collins v. Commissioner, 857 F.2d 1383, 1385 (9th Cir.1988). We affirm. 3 The Commissioner determined deficiencies in taxes against Befumo in the amount of $1,756 for tax year 1985 and $934 for tax year 1986. The Commissioner also assessed additions to taxes pursuant to 26 U.S.C. §§ 6651…