Ronald Satterlee v. IRS, et al., No. 06-3776 (8th Cir. 2007)
Annotate this CaseCourt Description: Civil case - federal tax. District court did not err in dismissing without prejudice plaintiff's action challenging the results of a collection due process hearing related to plaintiff's tax deficiencies.
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United States Court of Appeals FOR THE EIGHTH CIRCUIT ___________ No. 06-3776 ___________ Ronald L. Satterlee, * * Appellant, * * v. * Appeal from the United States * District Court for the Internal Revenue Service; United States * Western District of Missouri. of America; Commissioner of Internal * Revenue Service, * [UNPUBLISHED] * Appellees. * ___________ Submitted: September 25, 2007 Filed: October 25, 2007 ___________ Before MURPHY, SMITH, and SHEPHERD, Circuit Judges. ___________ PER CURIAM. Ronald L. Satterlee appeals the district court s1 dismissal without prejudice of his action challenging the result of a collection due process hearing relating to tax deficiencies and a civil penalty assessed against him. Upon this court s de novo review, we conclude dismissal was proper for the reasons given by the district court. See Ferris, Baker Watts, Inc. v. Ernst & Young, L.L.P., 395 F.3d 851, 853 (8th Cir. 1 The Honorable Richard E. Dorr, United States District Judge for the Western District of Missouri. 2005) (Fed. R. Civ. P. 12(b)(6) dismissal standard of review). We also conclude the district court did not abuse its discretion in denying Satterlee s motion to reconsider. See MIF Realty, L.P. v. Rochester Associates, 92 F.3d 752, 755 (8th Cir. 1996) (standard of review). Accordingly, we affirm. See 8th Cir. R. 47B. ______________________________ -2-
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