James B. Smith Jean T. Smith v. Commissioner of Internal Revenue Service

978 F.2d 716 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. James B. SMITH; Jean T. Smith, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70168. United States Court of Appeals, Ninth Circuit. Submitted Oct. 22, 1992. * Decided Oct. 27, 1992. Before SNEED, BEEZER and WIGGINS, Circuit Judges. 1 MEMORANDUM ** 2 James B. and Jean T. Smith appeal pro se the tax court's decision upholding the Commissioner of Internal Revenue's determination of tax deficiencies and additions to tax for the tax years 1974 through 1985. We have jurisdiction pursuant to 26 U.S.C. § 7482 (a). We review the tax court's conclusions of law de novo and findings of fact for clear error. Collins v. Commissioner, 857 F.2d 1383, 1385 (9th Cir.1988). We affirm. 3 * The Commissioner's deficiency determinations as to the taxes and penalties owed by the Smiths are presumed correct. See Hokanson v. Commissioner, 730 F.2d 1245, 1249 (9th Cir.1984).…