Phillip S. Fry and K. Susan Fry v. Commissioner, Internal Revenue Service

8 F.3d 26 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Phillip S. FRY and K. Susan Fry, Petitioners-Appellants, v. COMMISSIONER, INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 91-70560. United States Court of Appeals, Ninth Circuit. Argued and Submitted Feb. 3, 1993. Decided Oct. 4, 1993. Before: FARRIS, POOLE and WIGGINS, Circuit Judges. 1 MEMORANDUM * 2 Appellants Phillip and K. Susan Fry appeal from the Tax Court's assessment of tax deficiencies and supplemental taxes for the tax years 1977 through 1980. They challenge the court's computation of their income and its disallowance of their claimed deductions. They also challenge the court's finding that their returns were fraudulent, and they object to the court's rejection of an untimely 138-page reply brief. The Tax Court had jurisdiction over this case pursuant to 26 U.S.C. §§ 6213-14 , 7442. Our jurisdiction comes from 26 U.S.C. § 7482 . We now affirm. I. The Rejected Reply Brief 3 The Frys…