Robert W. Bass v. Commissioner of Internal Revenue Service

976 F.2d 736 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Robert W. BASS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 91-70709. United States Court of Appeals, Ninth Circuit. Submitted Sept. 15, 1992. Decided Sept. 22, 1992. Before GOODWIN, D.W. NELSON and REINHARDT, Circuit Judges. 1 MEMORANDUM ** 2 Robert W. Bass, appeals pro se the tax court's dismissal of his petition for redetermination of the Commissioner of Internal Revenue's ("CIR") determination of a deficiency for tax year 1986. The tax court found it lacked jurisdiction because Bass's petition was not timely filed pursuant to 26 U.S.C. §§ 6212 & 6213. We have jurisdiction pursuant to 26 U.S.C. § 7482 (a) and affirm. 3 We review the issue of the tax court's jurisdiction de novo. Kelly v. Commissioner, 877 F.2d 756, 757 (9th Cir.1989). The tax court's findings regarding the dates on which the notice of deficiency and the petition for…