Thomas M. Kerr, Petitioner-appellant, v. Commissioner of Internal Revenue, Respondent-appellee, 73 F.3d 369 (9th Cir. 1995)

MEMORANDUM^** 

Thomas M. Kerr appeals pro se the tax court's judgment upholding the Commissioner of Internal Revenue's determination of deficiencies in his federal income taxes and imposition of additions to tax for fraud pursuant to 26 U.S.C. § 6653(b). We have jurisdiction pursuant to 26 U.S.C. § 7482, and we affirm for the reasons stated by the tax court in its memorandum opinion filed November 30, 1994.

We grant the Commissioner's request for sanctions in the amount of $2000 because this appeal is frivolous. See 28 U.S.C. § 1912; Fed. R. App. P. 38; Smith v. Commissioner, 800 F.2d 930, 936 (9th Cir. 1986).

AFFIRMED WITH SANCTIONS.