Donald E. Jones v. Commissioner of Internal Revenue

104 F.3d 365 79 A.F.T.R.2d 97 -355 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Donald E. JONES, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 96-70598. United States Court of Appeals, Ninth Circuit. Submitted Dec. 16, 1996. * Decided Dec. 20, 1996. Before: SNEED, TROTT, and THOMAS, Circuit Judges. 1 MEMORANDUM ** 2 Taxpayer Donald E. Jones appeals pro se the United States Tax Court's dismissal of his petition challenging the Commissioner of Internal Revenue's ("CIR") notice of deficiency for the tax years 1989 through 1995 for lack of jurisdiction. We review de novo, Scar v. C.I.R., 814 F.2d 1363, 1366 (9th Cir.1987), and we affirm. 3 It is well-established that the tax court is a court of limited jurisdiction and that the tax court may exercise its jurisdiction only when the IRS issues a notice of deficiency and the taxpayer files a timely petition for redetermination. See 26 U.S.C. § 6213 (a); Scar, 814 F.2d at 1366 . The…