Keenan
Keenan v. Commissioner
Opinion
Lead Opinion
MEMORANDUM **
Robert B. Keenan appeals pro se from the tax court’s decision in favor of the Commissioner of Internal Revenue (“Commissioner”) in his action contesting the notice of deficiency for tax year 2000. We have jurisdiction pursuant to 26 U.S.C. § 7482 . We review the tax court’s conclusions of law de novo and its findings of fact for clear error. Emert v. Commissioner, 249 F.3d 1130, 1131 (9th Cir.2001). We review the tax court’s decision entering a deficiency computation under Tax Court Rule 155 for abuse of discretion. Erhard v. Comm’r, 46 F.3d 1470, 1479 (9th Cir.1995). We affirm.
Contrary to Keenan’s argument, the notice of deficiency was not invalid, because the Commissioner is not required to file a tax return on Keenan’s behalf prior to issuing the notice. See Roat v. Comm’r, 847 F.2d 1379 , 1381-82 (9th Cir.1988).
The tax court did not err by rejecting Keenan’s handwritten list of claimed deductions because he did not substantiate them with any documentation. See Geiger v. Comm’r, 440 F.2d 688, 689 (9th Cir.1971) (per.curiam) (rejecting taxpayer’s argument, based on her own testimony and absent supporting documentation, that she was entitled to…