Pantaleon Kolchev v. Commissioner of Internal Revenue Service

46 F.3d 1142 75 A.F.T.R.2d 95 -839 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Pantaleon KOLCHEV, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 94-70432. United States Court of Appeals, Ninth Circuit. Submitted: Jan. 25, 1995. * Decided: Feb. 1, 1995. Before: WALLACE, Chief Judge, HALL and KLEINFELD, Circuit Judges. 1 MEMORANDUM ** 2 Taxpayer Pantaleon Kolchev appeals pro se the tax court's summary judgment in favor of the Commissioner of Internal Revenue ("Commissioner"), in Kolchev's action seeking a redetermination of a tax deficiency and additions to tax for tax year 1990. We have jurisdiction under 26 U.S.C. Sec. 7482 , and we affirm. 3 * Summary Judgment 4 We review de novo the tax court's summary judgment in favor of the Commissioner. See Estate of Schnack v. Commissioner, 848 F.2d 933, 935 (9th Cir. 1988). The Commissioner's deficiency determinations as to the taxes and penalties owed by Kolchev are presumed…