Christian v. United States

17 F.3d 393 73 A.F.T.R.2d 94 -1378 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Henry CHRISTIAN, Jr., Plaintiff-Appellant, v. UNITED STATES of America, the Government of the United States; the U.S. Treasury Department; the Internal Revenue Service; State of California Franchise Tax Board, Defendants-Appellees. No. 93-55691. United States Court of Appeals, Ninth Circuit. Submitted Feb. 7, 1994. * Decided Feb. 17, 1994. Before: SCHROEDER, CANBY, and WIGGINS, Circuit Judges. 1 MEMORANDUM ** 2 Henry Christian, Jr. appeals pro se the district court's dismissal of his action against the Internal Revenue Service (IRS) for lack of subject matter jurisdiction and failure to state a claim. We have jurisdiction pursuant to 28 U.S.C. Sec. 1291 . The existence of subject matter jurisdiction is a question of law which we review de novo. Kruso v. International Tel. & Tel., 872 F.2d 1416 , 1421 (9th Cir.1989), cert. denied, 496 U.S. 937 (1990). We affirm. 3 On December 31, 1992,…