Elaine C. Chavez v. Commissioner Internal Revenue Service
Opinion
Opinion
978 F.2d 714 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Elaine C. CHAVEZ, Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70100. United States Court of Appeals, Ninth Circuit. Submitted Nov. 4, 1992. * Decided Nov. 6, 1992. Before SCHROEDER, FLETCHER and PREGERSON, Circuit Judges. 1 MEMORANDUM ** 2 Elaine C. Chavez 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 1983 through 1987. The tax court also imposed a $5000 penalty on Chavez pursuant to 26 U.S.C. § 6673 . We have jurisdiction under 26 U.S.C. § 7482 and affirm the tax court's decision and its imposition of a penalty. 3 * Standard of Review 4 We review the tax court's determinations of law de novo and its findings of fact for clear error. See Grimes v. Commissioner, 806 F.2d 1451, 1453 (9th Cir.1986) (standard of review for a tax court decision…