Gary G. Smith, Plaintiff-appellant, v. United States of America, Defendant-appellee, 942 F.2d 793 (9th Cir. 1991)
Annotate this CaseBefore HUG, WILLIAM A. NORRIS and NOONAN, Circuit Judges.
ORDER
We affirm the summary judgment of the district court. The record confirms that the Internal Revenue Service provided the taxpayer with all the required notices and properly assessed his taxes. No genuine issue of material fact exists concerning the lawfulness of the assessment. The amount of the deficiency was determined by the Tax Court and the principles of res judicata preclude review of that decision in this collateral proceeding.
AFFIRMED.
The panel unanimously finds this case suitable for decision without oral argument. Fed. R. App. P. 34(a) and 9th Cir.R. 34-4
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