Corinda Wertheim v. Commissioner of Internal Revenue Service

981 F.2d 1261 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Corinda WERTHEIM, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70426. United States Court of Appeals, Ninth Circuit. Submitted Dec. 21, 1992. * Decided Dec. 28, 1992. Before TANG, NOONAN and T.G. NELSON, Circuit Judges. 1 MEMORANDUM ** 2 Corinda Wertheim appeals pro se the tax court's decision affirming the Commissioner of Internal Revenue's (CIR) determination of deficiencies in income tax and additions to tax due for the tax years 1987 and 1988. Wertheim contends that the tax court erred by sustaining the CIR's determinations of deficiencies and additions to tax because section 6201(b)(1) of the Internal Revenue Code (Code) prohibits the assessment of estimated taxes. We have jurisdiction over appeals from the tax court pursuant to 26 U.S.C. § 7482 , and we affirm. 3 The tax court's interpretation of a statute is a ruling on a question of law which we…