Brent Jackson v. Commissioner Internal Revenue Service

990 F.2d 1258 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Brent JACKSON, Petitioner, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent. No. 92-70069. United States Court of Appeals, Ninth Circuit. Submitted Jan. 4, 1993. * Decided April 7, 1993. Before CHOY, GOODWIN and SKOPIL, Circuit Judges. 1 MEMORANDUM ** 2 Defendant Brent Jackson ("Jackson") appeals the tax court's dismissal of his petition for redetermination of a tax deficiency for failure to state a claim. Jackson contends that the tax court erred by dismissing his petition because (1) as a resident of California he is exempt from paying taxes, and (2) the Commissioner lacks the authority to collect taxes. We find these arguments without any merit and we affirm. I. Dismissal for Failure to State A Claim 3 We review de novo the tax court's dismissal for failure to state a claim upon which relief can be granted. Grimes v. Commissioner, 806 F.2d 1451, 1453 (9th Cir.1986). A dismissal on the pleadings is…