Larry Coleman v. CIR, No. 10-2546 (8th Cir. 2011)
Annotate this CaseCourt Description: Appeal for the U.S. Tax Court. Tax court order granting the Commissioner summary judgment on taxpayer's action challenging a Notice of Determination is affirmed without comment.
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United States Court of Appeals FOR THE EIGHTH CIRCUIT ___________ No. 10-2546 ___________ Larry Delano Coleman, * * Appellant, * * Appeal from the United States v. * Tax Court. * Commissioner of Internal Revenue, * [UNPUBLISHED] * Appellee. * ___________ Submitted: July 14, 2011 Filed: July 19, 2011 ___________ Before MURPHY, ARNOLD, and BENTON, Circuit Judges. ___________ PER CURIAM. Larry Coleman appeals the tax court s1 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 131 S. Ct. 86 (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 1 The Honorable Robert N. Armen, Jr., United States Tax Court Judge. Coleman s request for relief based on changed circumstances. See 26 U.S.C. ยง 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. ______________________________ -2-
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