Wayne L. Harlan Terri A. Harlan v. Commissioner of Internal Revenue

103 F.3d 138 78 A.F.T.R.2d 96 -7608, 97-1 USTC P 50,196 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Wayne L. HARLAN; Terri A. Harlan, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 96-70098. United States Court of Appeals, Ninth Circuit. Submitted Dec. 2, 1996. * Decided Dec. 06, 1996. Before: SNEED, TROTT, and THOMAS, Circuit Judges. 1 MEMORANDUM ** 2 Wayne L. Harlan appeals pro se the Tax Court's decision upholding in part the Commissioner of Internal Revenue's ("CIR") determination of deficiencies in his federal income taxes for the tax years 1986 and 1988. 1 Harlan contends that the Tax Court erred by upholding in part the CIR's determination of deficiencies because Harlan's testimony was sufficient to substantiate various expenses which he claimed on his return for tax year 1988. We have jurisdiction under I.R.C. § 7482. We review for clear error, Betson v. Commissioner, 802 F.2d 365, 367 (9th Cir.1986), and we affirm in…