Raymond A. Moorefield, Petitioner-appellant, v. Commissioner of Internal Revenue, Respondent-appellee, 133 F.3d 928 (9th Cir. 1997)

MEMORANDUM^* 

Raymond A. Moorefield appeals pro se the United States Tax Court's ("tax court") decision upholding the Commissioner of Internal Revenue's ("CIR") determination of federal income tax deficiencies in tax year 1988 and imposition of additions to tax. We have jurisdiction pursuant to 26 U.S.C. § 7482, and we affirm.

Moorefield contends that the tax court did not allow sufficient time at his hearing to present facts supporting an alleged conspiracy to deprive him of his rights. To the extent Moorefield argues that the tax court violated his procedural due process rights, we conclude that this contention lacks merit. See Stonecipher v. Bray, 653 F.2d 398, 403 (9th Cir. 1981) (stating that statutory scheme for contesting CIR's deficiency determinations comports with due process)

Moorefield's contention that he was improperly denied his right to a jury trial lacks merit. See Dawn v. Commissioner, 675 F.2d 1077, 1079 (9th Cir. 1982) (stating that taxpayers are not entitled to jury trial in tax court).

Moorefield abandoned all issues raised in his petition for redetermination challenging the Commissioner's determination of deficiencies and additions to tax by omitting these issues from his opening brief. See Wilcox v. Commissioner, 848 F.2d 1007, 1008 n. 2 (9th Cir. 1988).

AFFIRMED.¹