Keith James Ponthieux v. Commissioner of Internal Revenue Service

46 F.3d 1144 75 A.F.T.R.2d 95 -818, 95-1 USTC P 50,138 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Keith James PONTHIEUX, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 94-70363. 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 Keith James Ponthieux appeals pro se the tax court's dismissal of his petition for redetermination of tax deficiencies and additions for tax years 1990 and 1991. The tax court found that Ponthieux failed to allege any specific assignments of error in the Commissioner of Internal Revenue's ("Commissioner") calculation of his tax deficiency, as required under Tax Court Rule 34(b)(4) and (5). Ponthieux also appeals the tax court's imposition of a $5,000 penalty, pursuant to 26 U.S.C. Sec. 6673 . We have jurisdiction pursuant to 26 U.S.C. Sec. 7482 , and we affirm…