Dennis Roy Hacker v. Commissioner Internal Revenue Service

29 F.3d 632 74 A.F.T.R.2d 94 -5516 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Dennis Roy HACKER, Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 93-70923. United States Court of Appeals, Ninth Circuit. Submitted July 18, 1994. * Decided July 26, 1994. Before: FARRIS, KOZINSKI, and NOONAN, Circuit Judges. 1 MEMORANDUM ** 2 Taxpayer Dennis Roy Hacker appeals pro se the tax court's summary judgment in favor of the Commissioner of Internal Revenue ("Commissioner"), in Hacker's action seeking a redetermination of a tax deficiency and additions to tax. Hacker also appeals the tax court's imposition of a $5,000 penalty under 26 U.S.C. Sec. 6673 . We have jurisdiction under 26 U.S.C. Sec. 7482 , and we affirm both the summary judgment and the imposition of the penalty. 3 * Summary Judgment 4 We review de novo the tax court's summary judgment in favor of the Commissioner. Estate of Schnack v. Commissioner, 848 F.2d 933, 935 (9th…