Yousef Koulibaly v. Commissioner of Internal Revenue Service

52 F.3d 333 75 A.F.T.R.2d 95 -1730, 95-1 USTC P 50,267 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Yousef KOULIBALY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 94-70581. United States Court of Appeals, Ninth Circuit. Submitted April 4, 1995. * Decided April 10, 1995. Before: BROWNING, SNEED and T.G. NELSON, Circuit Judges. 1 MEMORANDUM ** 2 Taxpayer Yousef Koulibaly appeals pro se the tax court's summary judgment for the Commissioner of the Internal Revenue Service in Koulibaly's petition for redetermination of income tax deficiencies and additions to tax asserted against him by the Commissioner for the tax years 1981 through 1986. We have jurisdiction to review final orders of the tax court under 26 U.S.C. Sec. 7482 . Our review is de novo, Estate of Schnack v. Commissioner, 848 F.2d 933, 935 (9th Cir.1988), and we affirm. 3 Koulibaly contends that summary judgment was improper because genuine issues of material fact…