Merton W. Pekrul Linda L. Pekrul v. Commissioner of Internal Revenue Service

993 F.2d 884 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Merton W. PEKRUL; Linda L. Pekrul, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70761. United States Court of Appeals, Ninth Circuit. Submitted April 27, 1993. * Decided May 18, 1993. Before: BROWNING, KOZINSKI, and RYMER, Circuit Judges. 1 MEMORANDUM ** 2 Taxpayers Merton and Linda Pekrul appeal pro se the tax court's dismissal for failure to state a claim for relief of their petition for redetermination of tax deficiencies and additions to tax asserted against them by the Commissioner of Internal Revenue (Commissioner) for the tax years 1984, 1985 and 1988. The tax court also imposed a $2,500 penalty on the Pekruls under 26 U.S.C. § 6673 . We have jurisdiction under 26 U.S.C. § 7482 , and we affirm both the dismissal and the imposition of the penalty. We also impose $1,500 damages as a sanction against the Pekruls for filing a frivolous appeal. 3 We…