Lawrence K. Williams v. Commissioner of Internal Revenue Service

996 F.2d 1230 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Lawrence K. WILLIAMS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent. No. 92-70057. United States Court of Appeals, Ninth Circuit. Submitted June 18, 1993. * Decided June 23, 1993. 1 Before NORRIS and RYMER, Circuit Judges and TAYLOR ** , District Judge. 2 MEMORANDUM *** 3 Lawrence K. Williams appeals a decision by the United States Tax Court sustaining the Commissioner of Internal Revenue's disallowance of certain business deductions claimed by Williams on Schedules A and C of his 1985 federal income tax return. Williams also contests the Tax Court's determination that it lacked jurisdiction to award Williams a refund or credit for his overpayment of income tax for the 1982 tax year. We have jurisdiction under 26 U.S.C. § 7482 (a), and we affirm. 4 * Section 162 of the Internal Revenue Code provides a deduction for "ordinary and necessary" expenses incurred "during the taxable year in…