Donald R. Schramm v. Commissioner of Internal Revenue Service

988 F.2d 121 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Donald R. SCHRAMM, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70325. United States Court of Appeals, Ninth Circuit. Submitted Feb. 11, 1993. * Decided Feb. 22, 1993. Appeal from the United States Tax Court, Tax Ct. No. 13207-89. AFFIRMED. Before GOODWIN, SCHROEDER and CANBY, Circuit Judges. 1 MEMORANDUM ** 2 Donald Schramm appeals pro se the tax court's denial of his motion to revise the tax court's decision to impose 26 U.S.C. § 6673 sanctions of $10,000 on him for raising frivolous arguments in tax court in his petition challenging the Commissioner of Internal Revenue's (CIR) determination of deficiencies in income tax for the tax years 1985 and 1986. Schramm also contends that the amount of the sanctions exceeds the statutory maximum permissible at the time he filed his petition. We have jurisdiction under 26 U.S.C. § 7482 , and we affirm the…