Kimi Virginia Ikeda v. Commissioner Internal Revenue Service

35 F.3d 571 74 A.F.T.R.2d 94 -6188 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Kimi Virginia IKEDA, Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 93-70268. United States Court of Appeals, Ninth Circuit. Submitted Aug. 12, 1994. * Decided Aug. 31, 1994. Before: FLETCHER, HALL, and WIGGINS, Circuit Judges. 1 MEMORANDUM ** 2 On February 22, 1991, the Commissioner of the Internal Revenue Service ("Commissioner") issued a notice of deficiency to Kimi Virginia Ikeda ("Ikeda"), based on her failure to report income earned in 1988. The Commissioner assessed tax and penalties for failure to file a return, 26 U.S.C. Sec. 6651 (a)(1), negligence or intentional disregard of rules or regulations, 26 U.S.C. Sec. 6653 (a)(1), and failure to pay estimated taxes, 26 U.S.C. Sec. 6654 (a). Ikeda timely petitioned the tax court for a redetermination of the liabilities assessed by the notice of deficiency. After the Commissioner answered and Ikeda…