Bruce Buchbinder Elaine Buchbinder v. Commissioner Internal Revenue Service

999 F.2d 542 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Bruce BUCHBINDER; Elaine Buchbinder, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70114. United States Court of Appeals, Ninth Circuit. Submitted June 18, 1993. * Decided July 23, 1993. Before FAIRCHILD, ** BEEZER and WIGGINS, Circuit Judges. 1 MEMORANDUM *** OVERVIEW 2 The tax court granted a motion for partial summary judgment and a motion for entry of decision against the Buchbinders, disallowing two loss deductions claimed by the Buchbinders in their 1981 tax year. The taxpayers appeal. The tax court had jurisdiction pursuant to 26 U.S.C. §§ 6213 (a), 6214(a), and 7442. We have jurisdiction pursuant to 26 U.S.C. § 7482 . We affirm. STANDARD OF REVIEW 3 We review the tax court's grant of summary judgment de novo, see Estate of Schnack v. Commissioner, 848 F.2d 933, 935 (9th Cir.1988), and the imposition of sanctions under Tax Court Rule 104(c) for…