Jerry D. Webb v. Commissioner of Internal Revenue Service

46 F.3d 1149 75 A.F.T.R.2d 95 -820, 95-1 USTC P 50,127 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Jerry D. WEBB, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 94-70278. 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 Jerry D. Webb appeals pro se the tax court's decision affirming the Commissioner of Internal Revenue's ("Commissioner") determination of deficiencies in income tax and additions to tax for tax year 1989. Webb contends that the tax court lacked jursidction over his action because section 6201(b)(1) of the Internal Revenue Code ("Code") prohibits the assessment of estimated taxes. See 26 U.S.C. Sec. 6201 (b)(1). We have jurisdiction pursuant to 26 U.S.C. Sec. 7482 , and we affirm. 3 The tax court's interpretation of a statute is a ruling on a question of law which we review de…