Louis R. Tomburello Annette C. Tomburello v. Commissioner of Internal Revenue Service
Opinion
Opinion
988 F.2d 122 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Louis R. TOMBURELLO; Annette C. Tomburello, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent. No. 92-70440. United States Court of Appeals, Ninth Circuit. Submitted Feb. 22, 1993. * Decided March 1, 1993. Appeal from the United States Tax Court, Tax Ct. No. 10301-85. AFFIRMED WITH SANCTIONS. Before GOODWIN, SCHROEDER and CANBY, Circuit Judges. 1 MEMORANDUM ** 2 Louis R. and Annette C. Tomburello appeal pro se the tax court's decision upholding the Commissioner of Internal Revenue's (Commissioner) determination of a tax deficiency and additions to tax for the tax year 1981. 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 and impose damages in the amount of $1,000 against the Tomburellos for bringing a frivolous appeal. 3…