William R. Richardson v. Commissioner of Internal Revenue

91 F.3d 154 78 A.F.T.R.2d 96 -5266 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. William R. RICHARDSON, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 95-70781. United States Court of Appeals, Ninth Circuit. Submitted June 25, 1996. * Decided June 28, 1996. Before: NOONAN, LEAVY, and TASHIMA, Circuit Judges. 1 MEMORANDUM ** 2 William R. Richardson appeals pro se the Tax Court's decision upholding the Commissioner of Internal Revenue's ("Commissioner") determination of deficiencies and additions to tax in Richardson's federal income taxes for the tax years 1988 through 1990. We have jurisdiction pursuant under I.R.C. § 7482, and we affirm. 3 We review for clear error the Tax Court's finding that the taxpayer did not qualify for tax-exempt status. See, e.g., Church of Scientology v. Commissioner, 823 F.2d 1310, 1319 (9th Cir.1987), cert. denied, 486 U.S. 1015 (1988). 4 Richardson contends that the Tax Court clearly erred by finding…