Jeff Slama v. Commissioner of Internal Revenue Service
Opinion
Opinion
977 F.2d 591 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Jeff SLAMA, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70007. United States Court of Appeals, Ninth Circuit. Submitted Sept. 22, 1992. * Decided Oct. 5, 1992. Before GOODWIN, D.W. NELSON and REINHARDT, Circuit Judges. 1 MEMORANDUM ** 2 Jeff Slama appeals pro se the tax court's dismissal of his petition for redetermination of deficiency. The tax court found that it lacked jurisdiction to consider the petition because it was filed more than 90 days after the mailing of the notice of deficiency. We have jurisdiction pursuant to 26 U.S.C. § 7482 . We review de novo, Scar v. Commissioner, 814 F.2d 1363, 1366 (9th Cir.1987), and affirm. 3 Section 6212(a) of the Internal Revenue Code states in part: "If the Secretary determines that there is a deficiency in respect of any tax imposed ... he is authorized to send notice of such deficiency to the taxpayer by…