George Cameron Susan L. Cameron v. Commissioner Internal Revenue Service

15 F.3d 1083 73 A.F.T.R.2d 94 -786 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. George CAMERON; Susan L. Cameron, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70364. United States Court of Appeals, Ninth Circuit. Submitted Dec. 16, 1993. * Decided Jan. 4, 1994. As Amended on Denial of Rehearing Feb. 3, 1994. Before: GOODWIN, CANBY and KOZINSKI, Circuit Judges. 1 MEMORANDUM ** 2 Parties agree that taxpayers only owe a penalty under Internal Revenue Code Sec. 6661 1 for "a substantial understatement of income tax" if "income tax" is defined to include self employment taxes. Treasury Regulation 1.6661-(2) (d) (1) so defines "income tax". 3 As we defer to Treasury regulations that reasonably construe a statute, Pacific First Federal Savings Bank v. Commissioner, 961 F.2d 800, 804-05 (9th Cir.1992), amended, 1992 U.S.App. LEXIS 11517 (9th Cir.1992), we uphold Treasury Regulation 1.6661-(2)(d)(1). First, it is significant that…