Major
Major v. Commissioner of Internal Revenue
Opinion
Lead Opinion
MEMORANDUM **
Terry I. and Louise Major appeal pro se from the United States Tax Court’s order denying a motion to vacate the Tax Court’s denial of their petition for redetermination of federal income taxes owed for tax year 2001. We have jurisdiction under 26 U.S.C. § 7482 (a), and we affirm.
We review de novo the Tax Court’s conclusions of law, and its findings of fact for clear error. DHL Corp. v. Comm’r, 285 F.3d 1210 ,1216 (9th Cir.2002).
To the extent that the Majors contend that they are not taxpayers or persons subject to the jurisdiction of the Internal Revenue Service, we summarily reject such arguments. See United States v. Nelson (In re Becraft), 885 F.2d 547, 548 (9th Cir.1989) (commenting on the frivolity of arguments that challenge the application of the federal income tax laws to United States citizens).
The Tax Court did not err in upholding the Commissioner’s deficiency assessment. While the Commissioner proffered numerous documents evincing 2001 income for Mr. and Mrs. Major, their sole evidence *687 was bare denial of receipt of income and objection to the Commissioner’s evidence on Fifth Amendment grounds. Under these circumstances, the Tax Court properly…