Coleman v. Commissioner

Eighth Circuit

Coleman v. Commissioner

420 F. App'x 663

CourtCourt of Appeals for the Eighth Circuit

DecidedJuly 19, 2011

Docket10-2546

StatusUnpublished

Cited by11 cases

This text of 420 F. App'x 663 (Coleman v. Commissioner) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Coleman v. Commissioner, 420 F. App'x 663 (8th Cir. 2011).

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Opinion

*664 PER CURIAM.

Larry Coleman appeals the tax court’s 1 adverse grant of summary judgment in his action challenging a Notice of Determination issued by the Internal Revenue Service (IRS) Office of Appeals.

After carefully reviewing the record de novo, see Nestle Purina Petcare Co. v. Comm’r, 594 F.3d 968, 969 (8th Cir.), cert. denied — U.S. -, 131 S.Ct. 86, 178 L.Ed.2d 241 (2010), we conclude that summary judgment was appropriate for the reasons stated by the tax court, and we find no merit to Coleman’s arguments on appeal. We also decline to consider Coleman’s request for relief based on changed circumstances. See 26 U.S.C. § 6330(d)(2) (IRS Office of Appeals shall retain jurisdiction with respect to determination, including subsequent hearings, on issues regarding change in circumstances which affects such determination).

Accordingly, we affirm the tax court’s decision. See 8th Cir. R. 47B.

1

. The Honorable Robert N. Armen, Jr., United States Tax Court Judge.

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*664 PER CURIAM.

Larry Coleman appeals the tax court’s 1 adverse grant of summary judgment in his action challenging a Notice of Determination issued by the Internal Revenue Service (IRS) Office of Appeals.

After carefully reviewing the record de novo, see Nestle Purina Petcare Co. v. Comm’r, 594 F.3d 968, 969 (8th Cir.), cert. denied — U.S. -, 131 S.Ct. 86, 178 L.Ed.2d 241 (2010), we conclude that summary judgment was appropriate for the reasons stated by the tax court, and we find no merit to Coleman’s arguments on appeal. We also decline to consider Coleman’s request for relief based on changed circumstances. See 26 U.S.C. § 6330(d)(2) (IRS Office of Appeals shall retain jurisdiction with respect to determination, including subsequent hearings, on issues regarding change in circumstances which affects such determination).

Accordingly, we affirm the tax court’s decision. See 8th Cir. R. 47B.

1

. The Honorable Robert N. Armen, Jr., United States Tax Court Judge.

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420 F. App'x 663, Counsel Stack Legal Research, https://law.counselstack.com/opinion/coleman-v-commissioner-ca8-2011.

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