Sattar Nadjmechi v. Commissioner of Internal Revenue

77 F.3d 489 77 A.F.T.R.2d 96 -361, 96-1 USTC P 50,102 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Sattar NADJMECHI, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 94-70246. United States Court of Appeals, Ninth Circuit. Submitted Dec. 15, 1995. * Decided Jan. 5, 1996. Before: SCHROEDER, FERGUSON, and O'SCANNLAIN, Circuit Judges. 1 MEMORANDUM ** 2 Sattar Nadjmechi appeals pro se the judgment of the tax court. Specifically, Nadjmechi appeals the Tax Court's finding that he received $18.75 million in gross income from the illicit sale of heroin in 1985. The Tax Court's finding that Nadjmechi received $18.75 million in unreported income from narcotics sales is a finding of fact that must be upheld unless clearly erroneous. See Weimerskirch v. Commissioner, 596 F.2d 358, 360 (9th Cir.1979). 3 Generally, the Commissioner of Internal Revenue's determination of tax liability, as formally set forth in the statutory notice of deficiency, is…