Bruce Martin Dinsmore v. Commissioner Internal Revenue Service

78 F.3d 592 77 A.F.T.R.2d 96 -1004, 96-1 USTC P 50,177 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Bruce Martin DINSMORE, Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 94-70433. United States Court of Appeals, Ninth Circuit. Argued and Submitted Feb. 7, 1996. Decided Feb. 23, 1996. Before: POOLE, WIGGINS, and RYMER, Circuit Judges. 1 MEMORANDUM * 2 Bruce M. Dinsmore appeals pro se the Tax Court's holding in favor of the Commissioner of Internal Revenue ("Commissioner") on Dinsmore's challenge to the Commissioner's deficiency determinations on his 1985 and 1986 tax returns. The Commissioner disallowed Dinsmore's Schedule C deductions for business losses in 1985 and his Schedule E deductions for rental losses in 1985 and 1986, and assessed a five percent penalty for negligence for Dinsmore's 1985 and 1986 returns. The Tax Court upheld the deficiency finding and sustained the negligence penalty. We have jurisdiction pursuant to…