Reginald F. Whatley Cindy D. Whatley v. Commissioner of Internal Revenue Service

21 F.3d 1119 73 A.F.T.R.2d 94 -1775 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Reginald F. WHATLEY; Cindy D. Whatley, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 93-70274. United States Court of Appeals, Ninth Circuit. Submitted April 5, 1994. * Decided April 12, 1994. Before: POOLE, BEEZER, and T.G. NELSON, Circuit Judges. 1 MEMORANDUM ** 2 Reginald and Cindy Whatley appeal pro se the tax court's decision upholding the Commissioner of the Internal Revenue Service's ("IRS") (1) determination of federal income tax deficiencies for the tax years 1986 and 1987, and (2) imposition of additions to tax for negligence and substantial underpayment of income tax. We have jurisdiction under 26 U.S.C. Sec. 7482 (a)(1), and we affirm. 1 3 * Determination of Deficiencies 4 The Whatleys contend that the tax court erred by upholding the IRS's determination of deficiencies based on unreported income for 1986 and improper…