Richard Dykstra Julia Dykstra v. Commissioner of Internal Revenue
Cases that cite this one
5 later published cases cite this decision. The 4 that cite it most often are listed here.
- Gary Beecher Delores Beecher v. Commissioner of Internal Revenue (9th Cir. 2007)
- Beecher Cir (9th Cir. 2007)
- Haas & Associates v. Commissioner (9th Cir. 2003)
- DHL Corp. & Subsidiaries v. Commissioner (9th Cir. 2002)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion
OPINION
Richard and Julia Dykstra appeal pro se a decision of the Tax Court denying their petition challenging a deficiency of $224 for the 1996 tax year. We have jurisdiction pursuant to 26 U.S.C. § 7482. We review de novo the Tax Court’s interpretation of Treasury Regulations, see Idaho First Nat’l Bank v. Comm’r, 997 F.2d 1285, 1287 (9th Cir. 1993) (per curiam). We affirm.
The Dykstras challenge Treasury Regulation 1.79-3. We have reviewed the enabling statute, 26 U.S.C. § 79(c), the statute’s legislative history, H.R. Conf. Rep. No. 88-1149 (1964), reprinted in 1964 U.S.C.C.A.N. 1940, 1958-60, and the comments concerning the drafting of the regulation, T.D. 7924, 1984-1 C.B. 23-24. We agree with the Tax Court’s determination that the regulation was not arbitrary, capricious, or contrary to the intention of its enabling statute. See Chevron, U.S.A., Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837, 843-44, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984); Redlark v. Comm’r, 141 F.3d 936, 939-40 (9th Cir. 1998).
With respect to the Dykstras’ argument that the Tax Court violated their procedural rights in its handling of their case, there is nothing in the record to substantiate their contentions. See Sacks v. Comm’r, 82 F.3d 918, 921 (9th Cir. 1996); Sherman v. United States, 801 F.2d 1133, 1135 (9th Cir. 1986).
AFFIRMED.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.