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DIAL v. C.I.R.

No. 90-70231.

968 F.2d 898 (1992)

Don D. DIAL; Elizabeth A. Dial, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided June 30, 1992.

Attorney(s) appearing for the Case

Don D. Dial, Elizabeth A. Dial, in pro per.

Doris D. Coles, Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before: WRIGHT, CANBY, and WIGGINS, Circuit Judges.

CANBY, Circuit Judge.

Don Dial1 appeals a summary judgment of the Tax Court finding deficiencies in his federal income taxes for 1977, 1978, and 1979. We affirm.

BACKGROUND

During the years in question, Dial traded in Treasury bill futures contracts for his own account. As the Tax Court explained, Treasury bills are short-term debt obligations of the United States that are sold at a price discounted below face value....

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