Douglas Wayne Brown v. Commissioner of Internal Revenue

89 F.3d 844 77 A.F.T.R.2d 96 -2203, 96-1 USTC P 50,296 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Douglas Wayne BROWN, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 95-70111. United States Court of Appeals, Ninth Circuit. Submitted April 30, 1996. * Decided May 3, 1996. Before: BROWNING, REINHARDT, and FERNANDEZ, Circuit Judges. 1 MEMORANDUM ** 2 Douglas Wayne Brown appeals pro se the Tax Court's decision, after remand from this Court, upholding the Commissioner of Internal Revenue's ("Commissioner") determination of deficiencies in Brown's federal income taxes and additions to tax for failure to file tax returns, failure to pay estimated taxes and negligence for the years 1980 and 1981. We have jurisdiction pursuant to 26 U.S.C. § 7482 , and we affirm. 3 We review for clear error the Tax Court's finding that a taxpayer received income from illegal activities. Weimerskirch v. Commissioner, 596 F.2d 358, 359-60 (9th Cir.1979).…