Deborah R. Massie v. Commissioner of Internal Revenue

82 F.3d 423 77 A.F.T.R.2d 96 -1563, 96-1 USTC P 50,237 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Deborah R. MASSIE, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. No. 95-70448. United States Court of Appeals, Ninth Circuit. Submitted March 26, 1996. * Decided April 1, 1996. Before: GOODWIN, WIGGINS, and O'SCANNLAIN, Circuit Judges. 1 MEMORANDUM ** 2 Deborah R. Massie appeals pro se the tax court's order granting the Commissioner of Internal Revenue's ("CIR") motion to dismiss Massie's petition for redetermination for lack of jurisdiction. The tax court granted the CIR's motion to dismiss because Massie's petition for redetermination was not timely filed. We have jurisdiction under 26 U.S.C. § 7482 . We review the tax court's finding of fact that the notice of deficiency was mailed to Massie on August 30, 1991 under the clearly erroneous standard. King v. Commissioner, 857 F.2d 676, 679 (9th Cir.1988). The tax court's decision to admit certain…