Don Bear v. Commissioner of Internal Revenue Service

19 F.3d 26 73 A.F.T.R.2d 94 -1611 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Don BEAR, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 93-70509. United States Court of Appeals, Ninth Circuit. Submitted March 23, 1994. * Decided March 24, 1994. Before: FLETCHER, BRUNETTI, and TROTT, Circuit Judges. 1 MEMORANDUM ** 2 Don Bear appeals pro se the tax court's decision upholding the Commissioner of the Internal Revenue's ("Commissioner") determination of deficiencies in Bear's federal income tax and additions to tax due for the tax years 1984 through 1987. We have jurisdiction pursuant to 26 U.S.C. Sec. 7482 , and we affirm. 3 * Accord and Satisfaction of Tax Liabilities 4 Bear contends that he extinguished his 1984 and 1985 tax liabilities by tendering a check to the IRS in November 1985 which included on the back of the check: "Endorsement of this draft constitutes agreement that all taxes, interest, penalties, or other…