George B. Parks Marna C. Parks v. Commissioner of Internal Revenue

67 F.3d 308 76 A.F.T.R.2d 95 -6746, 95-2 USTC P 50,544 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. George B. PARKS; Marna C. Parks, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 94-70694. United States Court of Appeals, Ninth Circuit. Submitted Sept. 18, 1995. * Decided Sept. 22, 1995. Before: GOODWIN, WIGGINS, and O'SCANNLAIN, Circuit Judges. 1 MEMORANDUM ** 2 Taxpayers George and Marna Parks appeal pro se the Tax Court's decision, upholding the Commissioner of Internal Revenue's ("Commissioner") determination that the Parks were liable for a deficiency in income tax for tax year 1987. The Tax Court found that the Parks's had overstated the fair market value of a sailboat which they donated to the California Maritime Academy Foundation. The Parks also appeal the Tax Court's decision upholding the Commissioner's additions to tax for negligence under I.R.C. Sec. 6653(a)(1)(A) & (B), for making a valuation overstatement under…