Sentinel Financial Services, Lucille M. Haines, Trustee v. Commissioner Internal Revenue Service

39 F.3d 1188 74 A.F.T.R.2d 94 -6853 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. SENTINEL FINANCIAL SERVICES, Lucille M. Haines, Trustee, Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 93-70368. United States Court of Appeals, Ninth Circuit. Argued and Submitted Oct. 6, 1994. Decided Oct. 28, 1994. Before: WALLACE, Chief Judge, REINHARDT and BRUNETTI, Circuit Judges. MEMORANDUM 1 Sentinel Financial Services (Sentinel) appeals from the tax court's judgment upholding the determination by the Commissioner of the Internal Revenue Service (IRS) of federal income tax deficiencies for the tax years 1979 and 1980. We have jurisdiction over this timely appeal pursuant to 26 U.S.C. Sec. 7482 . We affirm. 2 The tax court's factual determination that a taxpayer has failed to present sufficient evidence to support a claimed deduction is reviewed for clear error. Norgaard v. Commissioner, 939 F.2d 874, 877 (9th Cir.1991) ( Norgaard ). 3…