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Full opinion text

PER CURIAM: The appeal is dismissed as legally frivolous. The issuance of a statutory notice of deficiency by the commissioner (which was never issued in this case) is necessary before the tax court has jurisdiction. See Corbett v. Frank, 9 Cir., 293 F.2d 501. If DaBoul was entitled to any relief, he should have proceeded in some United States district court.