Michael L. Rintoul v. Commissioner Internal Revenue Service

15 F.3d 1088 73 A.F.T.R.2d 94 -800 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Michael L. RINTOUL, Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70394. United States Court of Appeals, Ninth Circuit. Submitted Jan. 4, 1994. * Decided Jan. 12, 1994. 1 Before: POOLE and TROTT, Circuit Judges, and KING, ** District Judge. 2 MEMORANDUM *** 3 Taxpayer Michael Rintoul appeals pro se the tax court's dismissal for failure to state a claim of his petition for redetermination of tax deficiencies and additions to tax asserted against him by the Commissioner of the Internal Revenue Service ("Commissioner") for the tax years 1985, 1986, 1987, and 1988. The tax court also imposed a $5,000 penalty under 26 U.S.C. Sec. 6673 . We have jurisdiction under 26 U.S.C. Sec. 7482 , and we affirm both the dismissal and the imposition of the penalty. We also impose $1,500 damages as a sanction against Rintoul for filing a frivolous appeal. 4 We…