Roger W. Knight v. Commissioner of Internal Revenue Service

29 F.3d 632 74 A.F.T.R.2d 94 -5177 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Roger W. KNIGHT, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 93-70917. United States Court of Appeals, Ninth Circuit. Submitted June 21, 1994. * Decided June 24, 1994. Before: TANG, PREGERSON, and T.G. NELSON, Circuit Judges. 1 MEMORANDUM ** 2 Roger W. Knight appeals pro se the tax court's summary judgment for the Commissioner of the Internal Revenue Service ("Commissioner") in Knight's petition challenging the Commissioner's determination of an income tax deficiency against Knight for the tax year 1989. We have jurisdiction pursuant to 26 U.S.C. Sec. 7482 (a). We review de novo, see Dial v. Commissioner, 968 F.2d 898, 900 (9th Cir.1992), and affirm. 3 Knight and his ex-wife were separated in 1987 and obtained a divorce in 1991. Knight's ex-wife retained custody of their three dependent children from the time they were separated. In 1989,…