Bill Blankstyn v. Commissioner Internal Revenue Service

990 F.2d 1255 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Bill BLANKSTYN, Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70545. United States Court of Appeals, Ninth Circuit. Submitted March 10, 1993. * Decided March 19, 1993. Before WALLACE, Chief Judge, and FARRIS and BRUNETTI, Circuit Judges. 1 MEMORANDUM ** 2 Bill Blankstyn appeals pro se the tax court's dismissal of his petition for redetermination of a tax deficiency for the tax year 1985. The tax court found that it lacked jurisdiction to consider the petition because Blankstyn filed it more than 90 days after the mailing of the notice of deficiency. We have jurisdiction pursuant to 26 U.S.C. § 7482 . We review de novo, Scar v. Commissioner, 814 F.2d 1363, 1366 (9th Cir.1987), and affirm. 3 Section 6212(a) of the Internal Revenue Code states in part: "If the Secretary determines that there is a deficiency in respect of any tax imposed ... he is authorized to send…