Opinion
Because the panel unanimously finds this case suitable for decision without oral argument, Hart's request for oral argument is denied. See Fed. R.App. P. 34(a)(2).
NOT FOR PUBLICATION. (See Federal Rule of Appellate Procedure Rule 36-3)
After the United States Tax Court found taxpayer liable for income tax deficiencies and penalties and imposed sanctions against him for bringing frivolous proceedings, he appealed. The Court of Appeals held that determination of income subject to federal income tax and other liabilities was proper, and thus sanctions were warranted for appeal that was wholly without merit.
Affirmed with sanctions.
Page 991.
Appeal from the United States Tax Court.
Before KOZINSKI, T.G. NELSON, and TALLMAN, Circuit Judges.
This disposition is not appropriate for publication and may not be cited to or by the courts of this circuit except as may be provided by 9th Cir. R. 36-3.
Taxpayer Philip Lewis Hart appeals pro se the Tax Court's decision holding him liable for income tax deficiencies and penalties, and imposing sanctions against him under Internal Revenue Code § 6673 for bringing frivolous proceedings.
The Tax Court properly determined that Hart's wages and other income are subject to federal income tax, In Re Becraft, 885 F.2d 547, 548 (9th Cir.1989); Grimes v. Commissioner, 806 F.2d 1451, 1453 (9th Cir.1986) (per curiam), and that he was liable for additions to tax and accuracy-related penalties and sanctions pursuant to 26 U.S.C. §§ 72(t), 6651(a)(1), 6654, 6662(a) and 6673.
We grant the Commissioner's request for sanctions pursuant to Fed. R.App. P. 38 and 28 U.S.C. § 1912 in the amount of $2,000 because the result is obvious and Hart's appeal is wholly without merit. Olson v. United States, 760 F.2d 1003, 1005 (9th Cir.1985).
AFFIRMED WITH SANCTIONS.