Juergen Stengel v. Commissioner of Internal Revenue Service

996 F.2d 1227 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Juergen STENGEL, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70835. United States Court of Appeals, Ninth Circuit. Submitted June 8, 1993. * Decided June 18, 1993. Before CANBY, FERNANDEZ and T.G. NELSON, Circuit Judges. 1 MEMORANDUM ** 2 U.S.T.C., 1993 WL235192. 3 AFFIRMED. 4 Juergen Stengel appeals pro se the tax court's decision upholding the Commissioner of Internal Revenue's ("Commissioner") determination of income tax deficiencies for the tax years 1987, 1988, and 1989. The tax court also upheld the Commissioner's imposition of additions to Stengel's tax under former section 6653(a)(1) and current section 6662(b)(1) of the Internal Revenue Code. We have jurisdiction pursuant to 26 U.S.C. § 7482 (1988). We affirm. 5 In reviewing the tax court's decision to uphold the Commissioner's determination of deficiencies, we review the tax court's conclusions of…