Opinion
This panel unanimously finds this case suitable for decision without oral argument. See Fed. R.App. P. 34(a)(2).
NOT FOR PUBLICATION. (See Federal Rule of Appellate Procedure Rule 36-3)
John A. Graves, Las Vegas, NV, pro se.
Robert R. Di Trolio, Clerk, U.S. Tax Court, Donald L. Korb, Acting Chief Counsel Internal Revenue Service, Eileen J. O'Connor, Francesca Ugolini Tamami, U.S. Department of Justice, Washington, DC, for Respondent.
Appeal from a Decision of the United States Tax Court.
Before T.G. NELSON, SILVERMAN and BYBEE, Circuit Judges.
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.
A review of the record indicates that the questions raised in this appeal are so insubstantial as not to require further argument. See United States v. Hooton, 693 F.2d 857, 858 (9th Cir.1982) (per curiam) (stating standard).
Accordingly, we summarily affirm the Tax Court's judgment, and we grant respondent's motion for sanctions of $6,000 for pursuing a frivolous appeal. See 26 U.S.C. § 7482(c)(4); 28 U.S.C. § 1912; Fed. R.App. P. 38.
AFFIRMED.