Jerry Boyd v. Commissioner of Internal Revenue Service

91 F.3d 150 78 A.F.T.R.2d 96 -5766 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Jerry BOYD, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 95-70731. United States Court of Appeals, Ninth Circuit. Submitted July 9, 1996. * Decided July 15, 1996. Before: HUG, Chief Judge, and SCHROEDER and POOLE, Circuit Judges. 1 MEMORANDUM ** 2 Jerry Boyd appeals pro se the tax court's decision sustaining the deficiencies in and additions to tax asserted by the Commissioner of Internal Revenue for 1987 through 1991 and imposing a penalty of $10,000 on the ground that Boyd's petition seeking a redetermination was frivolous. 3 Boyd contends that the Commissioner's notice of deficiency was invalid because it was not based on a signed return (Boyd did not file returns for the years at issue), because it covered more than one year, and because it was not mailed within three years of the time the returns were due. Boyd also maintains that the tax…