James Widtfeldt v. CIR, No. 14-2382 (8th Cir. 2016)
Annotate this CaseCourt Description: Per Curiam - Before Loken, Murphy and Bye, Circuit Judges] U.S. Tax Court. The Commissioner properly determined that the taxpayer was not entitled to re-litigate the tax liability of his deceased mother's estate and there is no basis for reversal of the Tax Court's decisions.
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United States Court of Appeals For the Eighth Circuit ___________________________ No. 14-2382 ___________________________ James A. Widtfeldt lllllllllllllllllllllAppellant v. Commissioner of Internal Revenue lllllllllllllllllllllRespondent ___________________________ No. 14-2444 ___________________________ Estate of Gusteva Widtfeldt, Deceased, James A. Widtfeldt, Personal Representative llllllllllllllllllllAppellant v. Commissioner of Internal Revenue lllllllllllllllllllllAppellee ___________________________ No. 15-2166 ___________________________ Estate of Gusteva E. Widtfeldt, Deceased, James Widtfeldt, Statutory Executor lllllllllllllllllllllPetitioner v. Commissioner of Internal Revenue lllllllllllllllllllllRespondent ____________ Appeals from the United States Tax Court ____________ Submitted: March 7, 2016 Filed: March 11, 2016 [Unpublished] ____________ Before LOKEN, MURPHY, and BYE, Circuit Judges. ____________ PER CURIAM. In these consolidated appeals--two of which arise from actions that were dismissed as duplicating the first action--James Widtfeldt appeals the tax court’s grant of summary judgment to the Commissioner of Internal Revenue in a collection due process case. Following careful de novo review, we agree with the Commissioner that Widtfeldt was not entitled to re-litigate the tax liability of his deceased mother’s estate, and Widtfeldt has identified no basis for reversal. See 26 U.S.C. § 6330; Nestle Purina Petcare Co. v. Comm’r, 594 F.3d 968, 970 (8th Cir. 2010) (de novo review of tax court’s grant of summary judgment); Widtfeldt v. Comm’r, 449 Fed. Appx. 561 (8th Cir. Jan. 9, 2012) (unpublished per curiam). We also conclude that the tax court did not abuse its discretion in dismissing the duplicate actions. The rulings of the tax court are affirmed, see 8th Cir. R. 47B, and the Commissioner’s motion is denied as moot. ______________________________ -2-
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