John S. Carlson v. Commissioner of Internal Revenue Service

974 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NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. John S. CARLSON, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70010. United States Court of Appeals, Ninth Circuit. Submitted Aug. 24, 1992. * Decided Sept. 2, 1992. Before BRUNETTI, RYMER and KLEINFELD, Circuit Judges. 1 MEMORANDUM ** 2 John S. Carlson appeals pro se the tax court's decision granting judgment on the pleadings in favor of the Commissioner of the Internal Revenue Service in Carlson's petition for redetermination of deficiencies for tax year 1988 and imposing sanctions. We have jurisdiction pursuant to 26 U.S.C. § 7482 (a). We review de novo, Wilcox v. Commissioner, 848 F.2d 1007, 1008 (9th Cir.1988), and affirm the tax court's decision, as well as its imposition of sanctions. In addition, we award sanctions of $1,000 against Carlson pursuant to Fed.R.App.P. 38 and 28 U.S.C. § 1912 for bringing a frivolous appeal. 3 The tax court granted…