David Hoag v. Commissioner of Internal Revenue Service

15 F.3d 1085 73 A.F.T.R.2d 94 -633 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. David HOAG, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70461. United States Court of Appeals, Ninth Circuit. Submitted Dec. 6, 1993. * Decided Dec. 20, 1993. Before: SNEED, NOONAN, and TROTT, Circuit Judges. 1 MEMORANDUM ** 2 David Hoag appeals pro se the tax court's decision upholding the Commissioner of Internal Revenue's ("Commissioner") determination of a deficiency in Hoag's income tax due for the tax year 1987. The Commissioner determined a deficiency against Hoag on the ground he failed to report as income on his 1987 income tax return a California state income tax refund and a pension distribution he received in 1987. The tax court also upheld the Commissioner's imposition of additions to tax for negligence. We have jurisdiction pursuant to 26 U.S.C. Sec. 7482 (a). We affirm. 3 * The Commissioner's deficiency determination was…