YOUNG v. COMMISSIONER OF INTERNAL REVENUE (2020)

MEMORANDUM **

William L. Young appeals pro se from the Tax Court's order dismissing for lack of jurisdiction his petition regarding his tax liabilities for the 2007 to 2012 tax years. We have jurisdiction under 26 U.S.C. § 7482(a)(1). We review de novo. Gorospe v. Comm'r, 451 F.3d 966, 968 (9th Cir. 2006). We may affirm on any basis supported by the record. We affirm.

The Tax Court properly concluded that it lacked jurisdiction over Young's petition because the petition was untimely. See Scar v. Comm'r, 814 F.2d 1363, 1366 (9th Cir. 1987) (Tax Court may exercise its jurisdiction only when the IRS issues a notice of deficiency and the taxpayer files a timely petition for redetermination); Wilson v. Comm'r, 564 F.2d 1317, 1319 (9th Cir. 1977) (90-day period for petitioning the Tax Court commences on the date of mailing the notice of deficiency).

Contrary to Young's contention, the notices of deficiency were admissible under the public records exception. See Hansen v. United States, 7 F.3d 137, 138 (9th Cir. 1993) (discussing public records exception).

AFFIRMED.