William Irving Russell v. Commissioner of Internal Revenue
Opinion
Opinion
76 F.3d 388 76 A.F.T.R.2d 95 -8029, 96-1 USTC P 50,096 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. William Irving RUSSELL, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 94-70430. United States Court of Appeals, Ninth Circuit. Submitted Dec. 6, 1995. * Decided Dec. 11, 1995. Before: SNEED, TROTT, and HAWKINS, Circuit Judges. 1 MEMORANDUM ** 2 Taxpayer William Irving Russell appeals pro se the Tax Court's decision upholding in part the Commissioner of Internal Revenue's ("Commissioner") determination of federal income tax deficiencies for the tax years 1984, 1985, and 1986. The Commissioner limited Russell's claimed rental expenses with respect to Russell's home ("the Marymount property") to the amount such expenses did not exceed the rents received by Russell. The Commissioner also disallowed Russell's claim for a home office deduction. We review the Tax Court's findings of fact for clear error and its conclusions of law de novo.…