G. West Munz Anne C. Munz v. Commissioner Internal Revenue Service

972 F.2d 1341 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. G. West MUNZ; Anne C. Munz, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 91-70561. United States Court of Appeals, Ninth Circuit. Submitted Aug. 12, 1992. * Decided Aug. 20, 1992. Before BRUNETTI, RYMER and KLEINFELD, Circuit Judges. 1 MEMORANDUM ** 2 G. West Munz and Anne C. Munz appeal pro se the tax court's decision affirming the Commissioner of Internal Revenue's ("CIR") determination of a deficiency and additions to tax for tax year 1983. The Munzs contend that the tax court erred by finding that the CIR mailed the notice of deficiency within three years of the Munzs' filing of their 1983 federal income tax return as required by 26 U.S.C. § 6501 (a). We have jurisdiction pursuant to 26 U.S.C. § 7482 (a) and affirm. 3 * Standard of Review 4 We review the tax court's finding of fact under the clearly erroneous standard. See King v. Commissioner, 857 F.2d…