Rita Ann Wayno v. Commissioner of Internal Revenue Service

12 F.3d 1111 73 A.F.T.R.2d 94 -507 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Rita Ann WAYNO, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70536. United States Court of Appeals, Ninth Circuit. Submitted Nov. 17, 1993. * Decided Dec. 1, 1993. Before: SCHROEDER, D.W. NELSON, and THOMPSON, Circuit Judges. 1 MEMORANDUM ** 2 Rita Ann Wayno appeals pro se the Tax Court's decision upholding the Commissioner of Internal Revenue's ("Commissioner") determination of deficiency in income tax due for the 1986 tax year, plus additions to tax for negligence. We have jurisdiction under 26 U.S.C. Sec. 7482 (a). We affirm. 3 * Background 4 On April 15, 1987, Wayno and her husband (now deceased) filed a joint tax return for 1986. In March 1990, Wayno filed an amended tax return for 1986. Wayno's amended return reported deductible business expenses totalling $3,566 and "casualty" losses totalling $1,917,766. 1 On March 29, 1990, the…