Farhin Sanai v. Commissioner Internal Revenue Service

972 F.2d 1342 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Farhin SANAI, Petitioner-Appellant v. COMMISSIONER INTERNAL REVENUE SERVICE Respondent-Appellee No. 91-70383. United States Court of Appeals, Ninth Circuit. Submitted June 2, 1992. * Decided Aug. 12, 1992. Before POOLE, BRUNETTI and FERNANDEZ, Circuit Judges. 1 MEMORANDUM ** OVERVIEW 2 Farhin Sanai petitions for review of the Tax Court's decision finding a deficiency of $2,023,032 in her 1981 taxes stemming from unreported income. The facts leading up to this appeal have been set out in detail by the Tax Court in its opinion, 60 T.C.M. (CCH) 846 (1990), and will not be repeated here. ANALYSIS 3 Whether a rational foundation for deficiency determination exists is a factual question. Edelson v. Commissioner, 829 F.2d 828, 831 (9th Cir.1987). The Tax Court's findings only can be overturned on a showing that they are clearly erroneous. Id.; Adamson v. Commissioner, 745 F.2d 541, 546 (9th Cir.1984); Rockwell v.…