Tony L. Rust v. Commissioner Internal Revenue Service

974 F.2d 1343 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Tony L. RUST, Petitioner, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent. No. 91-70580. United States Court of Appeals, Ninth Circuit. Submitted Aug. 24, 1992. * Decided Sept. 1, 1992. Before BRUNETTI, RYMER and KLEINFELD, Circuit Judges. 1 MEMORANDUM ** 2 Tony L. Rust appeals pro se the tax court's decision upholding the Commissioner of Internal Revenue's ("CIR") determination of tax deficiencies and additions to tax for tax years 1984 through 1987. The tax court also imposed damages against Rust pursuant to 26 U.S.C. § 6673 . We have jurisdiction pursuant to 26 U.S.C. § 7482 (a) and affirm the tax court's decision and its imposition of damages. In addition, we impose sanctions of $1,000 against Rust pursuant to Fed.R.App.P. 38 and 28 U.S.C. § 1912 for bringing a frivolous appeal. 3 * Standard of Review 4 We review the tax court's determination of law de novo and its findings of fact for…