Patricia B. Farr v. Commissioner of Internal Revenue Service

41 F.3d 1513 74 A.F.T.R.2d 94 -6909 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Patricia B. FARR, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 93-70446. United States Court of Appeals, Ninth Circuit. Submitted Nov. 1, 1994. * Decided Nov. 10, 1994. Before: WALLACE, Chief Judge, GOODWIN and NORRIS, Circuit Judges. 1 MEMORANDUM ** 2 Taxpayer Patricia B. Farr appeals pro se the tax court's decision affirming the Commissioner of Internal Revenue's (CIR) determination of federal income tax deficiency for tax year 1987 and additions to tax for failure to file a tax return, negligence, and failure to pay estimated taxes. On appeal, Farr contends that the tax court erred by finding that (1) the notice of deficiency was valid, (2) Farr bore, and failed to meet, the burden of proving that the CIR's determination was incorrect, and (3) the additions to tax were properly assessed. We have jurisdiction under 26 U.S.C. Sec. 7482 , and…