John Albert Strand v. Commissioner of Internal Revenue Service

976 F.2d 738 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel.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 Albert STRAND, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent. No. 91-70653. 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 John Albert Strand appeals pro se the tax court's dismissal of his petition for redetermination of tax deficiencies for tax years 1976 and 1977. We have jurisdiction pursuant to 26 U.S.C. § 7482 (a). See Wilson v. Commissioner, cert. denied, 439 U.S. 832 (1978). We affirm. 3 * Background 4 On March 18, 1991, the Commissioner of Internal Revenue ("CIR") issued a notice of deficiency to Strand in which the CIR determined a tax deficiency and additions to tax for tax year 1984. On June 16, 1991, Strand filed a petition for a redetermination of tax deficiencies for tax years 1984, 1977, and 1976. 5 On August 9, 1991, the CIR filed a…