Kenneth F. Mattfeld, AKA Kenneth F. Mattfeld, Jr. v. Commissioner Internal Revenue Service

15 F.3d 1087 73 A.F.T.R.2d 94 -1167 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Kenneth F. MATTFELD, aka Kenneth F. Mattfeld, Jr., Petitioner, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent. No. 92-70578. United States Court of Appeals, Ninth Circuit. Argued and Submitted Jan. 31, 1994. Decided Feb. 7, 1994. Before: D.W. NELSON, REINHARDT, and BRUNETTI, Circuit Judges. 1 MEMORANDUM * 2 Taxpayer Kenneth Mattfeld ("Mattfeld") appeals the United States Tax Court's decision that he was not entitled to certain deductions on his returns for the taxable years 1986 and 1987, and that he was liable for additions to tax for substantial understatement of tax pursuant to 26 U.S.C. Sec. 6661 . The Commissioner of Internal Revenue (the "Commissioner") disallowed losses Mattfeld claimed as a result of his purchase and chartering of a sailboat. We AFFIRM the decision of the tax court, as we find that the court did not clearly err by deciding that Mattfeld did not have an actual…