Michael S. Fair v. Commissioner of Internal Revenue Service

60 F.3d 833 76 A.F.T.R.2d 95 -5724, 95-2 USTC P 50,418 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Michael S. FAIR, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 94-70558. United States Court of Appeals, Ninth Circuit. Submitted June 26, 1995. * Decided June 30, 1995. Before: O'SCANNLAIN, LEAVY, and HAWKINS, Circuit Judges. 1 MEMORANDUM ** 2 Taxpayer Michael Samuel Fair appeals pro se the tax court's summary judgment for the Commissioner of Internal Revenue ("CIR") in Fair's action contesting the CIR's determinations of tax deficiencies and additions to tax for the tax years 1983, 1987, and 1988, and the tax court's imposition of a $2,500 penalty for Fair's filing of a frivolous petition. The CIR determined Fair's tax deficiencies after Fair tardily filed his tax returns and failed to report income he received during the relevant tax years. We have jurisdiction pursuant to 26 U.S.C. Sec. 7482 . We review de novo, Estate of…