John R. Walsh, Jr. Marcy W. Walsh v. Commissioner Internal Revenue Service

72 F.3d 136 76 A.F.T.R.2d 95 -7714, 96-1 USTC P 50,024 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. John R. WALSH, Jr.; Marcy W. Walsh, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 94-70361. United States Court of Appeals, Ninth Circuit. Argued and Submitted Nov. 13, 1995. Decided Nov. 27, 1995. 1 Before: SCHROEDER and ALARCON, Circuit Judges, and PANNER, * Senior District Judge. 2 MEMORANDUM ** 3 John R. Walsh, Jr. and Marcy W. Walsh (collectively "Walsh") appeal from the order of the Tax Court granting summary judgment in favor of the Commissioner of Internal Revenue ("Commissioner") in Walsh's petition contesting the Commissioner's disallowance of certain losses allegedly suffered by Walsh while investing with First Western Government Securities, Inc. ("First Western"). Walsh also appeals from the Tax Court's order imposing sanctions pursuant to 26 U.S.C. Sec. 6673 (a)(1). 4 Because Walsh failed to provide the necessary…