Robert C. Jacobsen Carol S. Jacobsen v. Commissioner of Internal Revenue

103 F.3d 138 78 A.F.T.R.2d 96 -7453 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Robert C. JACOBSEN; Carol S. Jacobsen, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 95-70401. United States Court of Appeals, Ninth Circuit. Submitted Nov. 18, 1996. * Decided Nov. 20, 1996. Before: PREGERSON, REINHARDT, and T.G. NELSON, Circuit Judges. 1 MEMORANDUM ** 2 Robert C. Jacobsen and Carol S. Jacobsen (the "Jacobsens") appeal pro se the Tax Court's decision upholding the Commissioner of Internal Revenue's (the "Commissioner") determination of deficiencies in their federal income taxes for the tax year 1991. We have jurisdiction under 26 U.S.C. § 7482 (a). We review for clear error, Norgaard v. Commissioner, 939 F.2d 874, 877 (9th Cir.1991), and we affirm. 3 Here, the Tax Court upheld the Commissioner's disallowance of the deductions at issue because the Jacobsens failed to offer any evidence at trial substantiating the deductions. Because the…