Robert E. Williams v. Commissioner Internal Revenue Service

24 F.3d 252 73 A.F.T.R.2d 94 -2120 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Robert E. WILLIAMS, Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 92-70700. United States Court of Appeals, Ninth Circuit. Submitted May 12, 1994. * Decided May 17, 1994. Before: FERGUSON, NOONAN, and T.G. NELSON, Circuit Judges. 1 MEMORANDUM ** 2 Robert E. Williams (Williams) timely petitions for review of the Tax Court's decision entered on July 7, 1992 as to Williams's 1987 federal tax returns. We have jurisdiction under 26 U.S.C. Sec. 7482 and affirm. 3 The Tax Court concluded that Williams had erred in computing the depreciation deductions for his San Francisco, California, and Savannah, Georgia, rental properties in his 1987 federal tax returns. The Tax Court reasoned that "[a]s a result of these errors, which the Court believes were inadvertent, [Williams] computed the basis of the San Francisco property to be $111,000.00, and that of the…