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LOUIS v. C.I.R.

No. 96-70808.

170 F.3d 1232 (1999)

John R. LOUIS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided March 24, 1999.

Attorney(s) appearing for the Case

Edward O.C. Ord and Christian M. Winther, Ord & Norman, San Francisco, California, for petitioner-appellant.

Theodore M. Doolittle, United States Department of Justice, Washington, D.C., for respondent-appellee.

Before: BROWNING, PREGERSON, and HAWKINS, Circuit Judges.

PER CURIAM:

After conviction and punishment for tax fraud during the years 1977 and 1978, John R. Louis ("Louis") challenges the IRS's imposition under 26 U.S.C. § 6653(b) of additions to tax for fraud for the years 1976, 1977 and 1978 as violative of: (1) the Double Jeopardy Clause; (2) the Eighth Amendment; and (3) the Fifth and Sixth Amendments. We review the tax court's rejection of Louis's challenges de novo and affirm.

I.

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