Phuoc G. Cao Nghia T. Le v. Commissioner Internal Revenue Service

78 F.3d 594 77 A.F.T.R.2d 96 -1113, 96-1 USTC P 50,167 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Phuoc G. CAO; Nghia T. Le, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 94-70487. United States Court of Appeals, Ninth Circuit. Submitted Feb. 9, 1996. * Decided Feb. 29, 1996. Before: POOLE, WIGGINS, and RYMER, Circuit Judges. 1 MEMORANDUM ** 2 Phuoc Cao and his wife, Nghia Le, appeal pro se the Tax Court's decision, upholding certain deficiency determinations and penalty assessments made by the Commissioner of Internal Revenue ("Commissioner") with respect to their 1987 joint federal tax return. We have jurisdiction pursuant to 28 U.S.C. § 7482 (a)(1) (1994), and we affirm. FACTS 3 This appeal involves deductions claimed by Cao and Le (collectively "taxpayers") for the 1987 tax year. Cao, an electronic technician, started selling real estate in 1987. In the same year, Le started working as a mortgage broker. After…