Helen Lisle v. United States

73 F.3d 369 77 A.F.T.R.2d 96 -359 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Helen LISLE, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee. No. 94-17197. United States Court of Appeals, Ninth Circuit. Submitted Dec. 19, 1995. * Decided Dec. 27, 1995. Before: SNEED, TROTT, and HAWKINS, Circuit Judges. 1 MEMORANDUM ** 2 Helen Lisle appeals pro se the district court's summary judgment for the United States in Lisle's action seeking a tax refund of her federal income taxes for the years 1979 through 1985. Lisle claims that the Commissioner of Internal Revenue's (the "CIR") deficiency determinations for the years at issue were invalid because the CIR failed to determine whether Lisle was a citizen, resident alien, or nonresident alien and whether the source of Lisle's income was derived from within the United States. We have jurisdiction pursuant to 28 U.S.C. Sec. 1291 . We review de novo, see Jesinger v. Nevada Fed. Credit Union, 24 F.3d 1127, 1130…