Greene

MEMORANDUM

Russell Greene appeals pro se the decision of the Tax Court upholding the Commissioner of Internal Revenue’s determination of deficiencies in income tax for tax years 1992 through 1996. We have jurisdiction pursuant to 26 U.S.C. §§ 7482 , 7483, and we affirm.

We review the tax court’s conclusions of law de novo and its findings of fact for clear error. See Boyd Gaming Corp. v. Commissioner, 177 F.3d 1096, 1098 (9th Cir.1999). Because Greene stipulated to the Commissioner’s evidence that he received wages and compensation but did not file tax returns during those years, the Tax Court did not err by holding that Greene was liable for the tax deficiencies pursuant to 26 U.S.C. § 61 (a) and for statutory penalties pursuant to 26 U.S.C. § 6651 (a)(1). Greene’s contentions that his income was not taxable and that the government lacked authority to assess the deficiency are entirely without merit. See Wilcox v. Commissioner, 848 F.2d 1007, 1008 (9th Cir.1988).

We reject Greene’s contention that this ease must be remanded because the Tax Court failed to rule on his motion to dismiss the petition for lack of jurisdiction, which he filed after the Tax Court entered a…