Opinion
No. 10-2546.
Submitted: July 14, 2011.
Filed: July 19, 2011.
Appeal from the United States Tax Court.
Larry Delano Coleman, Kansas City, MO, pro se.
Thomas J. Clark, John A. Dicicco, Richard Farber, Robert William Metzler, Supervisory, Curtis Clarence Pett, Gilbert Steven Rothenberg, Deputy, U.S. Department of Justice, William Wilkins, Internal Revenue Service, Washington, DC, Dennis Onnen, U.S. Internal Revenue Service, Kansas City, MO, for Appellee.
Before MURPHY, ARNOLD, and BENTON, Circuit Judges.
[UNPUBLISHED]
Larry Coleman appeals the tax court's adverse grant of summary judgment in his action challenging a Notice of Determination issued by the Internal Revenue Service (IRS) Office of Appeals.
The Honorable Robert N. Armen, Jr., United States Tax Court Judge.
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.