Iris Dugow v. Commissioner Internal Revenue Service

64 F.3d 666 76 A.F.T.R.2d 95 -6012, 95-2 USTC P 50,482 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Iris DUGOW, Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 94-70083. United States Court of Appeals, Ninth Circuit. Submitted Aug. 11, 1995. * Decided Aug. 15, 1995. Before: THOMPSON, LEAVY, and TROTT, Circuit Judges. 1 MEMORANDUM ** 2 Iris Dugow ("Taxpayer") appeals from the Tax Court's decision upholding the Commissioner's imposition of certain additions to underlying and undisputed tax liabilities, arguing that the facts do not support the finding that Taxpayer was negligent and acted unreasonably by relying on the advice of others. We affirm. 3 * During the time in question (i.e., for tax years 1981 and 1982), sections 6653(a)(1) and 6653(a)(2) of the 1954 Internal Revenue Code (as amended) provided that the Commissioner could assess an addition to tax equal to 5% of the underpaid amount, and an extra 50% of the interest…