Robert C. Kersey v. Commissioner of Internal Revenue Service

50 F.3d 15 75 A.F.T.R.2d 95 -1443, 95-1 USTC P 50,181 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Robert C. KERSEY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 94-70369. United States Court of Appeals, Ninth Circuit. Submitted March 7, 1995. * Decided March 9, 1995. Before: SNEED, POOLE, and BRUNETTI, Circuit Judges. 1 MEMORANDUM ** 2 Robert C. Kersey appeals pro se the tax court's decision sustaining the Internal Revenue Service's ("IRS") determination of a deficiency in Kersey's federal income taxes for the tax year 1989. Kersey also appeals the tax court's decision upholding the IRS's imposition of additions to tax for negligence pursuant to 26 U.S.C. Sec. 6662 . We have jurisdiction pursuant to 26 U.S.C. Sec. 7482 , and we affirm. 3 Kersey contends that the tax court erred by finding that the educational expenses he incurred in pursuing a bachelor degree of science in management were not deductible as "ordinary and…