George
George v. Commissioner
Opinion
Lead Opinion
MEMORANDUM **
Richard E. George appeals pro se from a decision of the tax court determining tax deficiency for 1997 and imposing penalties. We have jurisdiction pursuant to 26 U.S.C. § 7482 (a), and we affirm in part, and vacate and remand in part.
We review de novo the tax court’s conclusions of law and for clear error its findings of fact. Kelley v. Comm’r, 45 F.3d 348 , 350 (9th Cir.1995). We review for abuse of discretion imposition of penalties and evidentiary sanctions. See Larsen v. Comm’r, 765 F.2d 939, 941 (9th Cir. 1985) (per curiam) (imposition of penalties pursuant to 26 U.S.C. § 6673 ); Smith v. Comm’r, 800 F.2d 930, 934 (1986) (imposition of evidentiary sanctions).
The tax court properly found that George is subject to the federal system of *935 taxation. See, e.g., United States v. Romero, 640 F.2d 1014, 1016 (9th Cir.1981). The tax court acted within its discretion to impose a penalty under 26 U.S.C. § 6673 because George pursued frivolous claims for purpose of delay. See Grimes v. Comm’r, 806 F.2d 1451, 1454 (9th Cir.1986) (per curiam). The tax court properly disallowed the deductions George urged in his proposed amended tax return, because George did not…