Stuart Seligson v. Commissioner of Internal Revenue Service

15 F.3d 1089 73 A.F.T.R.2d 94 -784 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Stuart SELIGSON, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70634. United States Court of Appeals, Ninth Circuit. Submitted Dec. 20, 1993. * Decided Jan. 6, 1994. Before: SNEED, NOONAN, and TROTT, Circuit Judges. 1 MEMORANDUM ** 2 Stuart Seligson appeals pro se the tax court's decision upholding the Commissioner of Internal Revenue's ("Commissioner") determination of tax deficiency and additions to tax for the tax year 1986. We have jurisdiction under 26 U.S.C. Sec. 7482 (a), and we affirm. 3 * Tax Deficiency 4 Seligson contends the determination of a tax deficiency in 1986 was erroneous because he was not required to recognize taxable income, interest, and dividends distributable to him from a trust created for his benefit because the trust was a complex trust. This contention lacks merit. 5 The Tax Court's findings that a trust was a…