United States v. Michael Cowles

MEMORANDUM **

In this tax collection action, Michael Cowles appeals from the district court’s grant of summary judgment in favor of the Government. Because the parties are familiar with the facts and procedural history of this case, we repeat only those facts necessary to resolve the issues raised on appeal. We affirm.

Cowles contends that the district court erred in not permitting him to challenge the amount of the estate’s tax liability in this case. But, as the district court correctly concluded, only the estate itself, and not an interested third party, may contest the tax assessment. See…