Scott R. Philips v. Commissioner of Internal Revenue

Ninth Circuit

Scott R. Philips v. Commissioner of Internal Revenue

99 F.3d 1146, 1996 U.S. App. LEXIS 40435, 1996 WL 593497

CourtCourt of Appeals for the Ninth Circuit

DecidedOctober 15, 1996

Docket96-70113

StatusUnpublished

Cited by1 cases

This text of 99 F.3d 1146 (Scott R. Philips v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Scott R. Philips v. Commissioner of Internal Revenue, 99 F.3d 1146, 1996 U.S. App. LEXIS 40435, 1996 WL 593497 (9th Cir. 1996).

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Opinion

99 F.3d 1146

78 A.F.T.R.2d 96-6997, 96-2 USTC P 50,594

NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel.
Scott R. PHILIPS, Petitioner-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

No. 96-70113.

United States Court of Appeals, Ninth Circuit.

Submitted Oct. 7, 1996.*
Decided Oct. 15, 1996.

Before: BEEZER, KOZINSKI, and KLEINFELD, Circuit Judges.

MEMORANDUM**

Scott R. Philips appeals pro se from a decision of the tax court upholding the Commissioner of Internal Revenue's deficiency determinations and additions to tax for tax years 1987 through 1991. In his petition and amended petitions for a redetermination of the deficiencies, Philips set forth no facts to support his claim of error in the deficiency determinations and advanced only frivolous legal arguments, including that he was not a taxpayer, that his wages are not taxable under the Internal Revenue Code, and that the income tax violates the Sixteenth Amendment because it is an "indirect" excise tax.

We affirm the tax court's decision for the reasons set forth in its Memorandum Findings of Fact and Opinion filed November 14, 1995. Philips' assertion on appeal that he was denied due process due to bias by both the Internal Revenue Service and the tax court is not supported by the record.

We DENY the Commissioner's motion for imposition of sanctions on appeal pursuant to Fed.R.App.P. 38.

AFFIRMED.1

*

The panel unanimously finds this case suitable for decision without oral argument. Fed.R.App.P. 34(a); 9th Cir.R. 34-4

**

This disposition is not appropriate for publication and may not be cited to or by the courts of this circuit except as provided by 9th Cir.R. 36-3

1

Philips' request for oral argument is denied

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99 F.3d 1146

78 A.F.T.R.2d 96-6997, 96-2 USTC P 50,594

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.
Scott R. PHILIPS, Petitioner-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

No. 96-70113.

United States Court of Appeals, Ninth Circuit.

Submitted Oct. 7, 1996.*
Decided Oct. 15, 1996.

Before: BEEZER, KOZINSKI, and KLEINFELD, Circuit Judges.

MEMORANDUM**

Scott R. Philips appeals pro se from a decision of the tax court upholding the Commissioner of Internal Revenue's deficiency determinations and additions to tax for tax years 1987 through 1991. In his petition and amended petitions for a redetermination of the deficiencies, Philips set forth no facts to support his claim of error in the deficiency determinations and advanced only frivolous legal arguments, including that he was not a taxpayer, that his wages are not taxable under the Internal Revenue Code, and that the income tax violates the Sixteenth Amendment because it is an "indirect" excise tax.

We affirm the tax court's decision for the reasons set forth in its Memorandum Findings of Fact and Opinion filed November 14, 1995. Philips' assertion on appeal that he was denied due process due to bias by both the Internal Revenue Service and the tax court is not supported by the record.

We DENY the Commissioner's motion for imposition of sanctions on appeal pursuant to Fed.R.App.P. 38.

AFFIRMED.1

*

The panel unanimously finds this case suitable for decision without oral argument. Fed.R.App.P. 34(a); 9th Cir.R. 34-4

**

This disposition is not appropriate for publication and may not be cited to or by the courts of this circuit except as provided by 9th Cir.R. 36-3

1

Philips' request for oral argument is denied

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