Legal Opinion

Parks v. Commissioner

Court of Appeals for the Ninth Circuit

Decided September 15, 2006No. 05-70783Published

1Opinion of the Court

MEMORANDUM **

Wayne Parks appeals pro se from the Tax Court’s dismissal of his “small tax” action. We dismiss for lack of jurisdiction.

Under I.R.C. § 746303), a decision entered in a “small tax” case “shall not be reviewed in any other court.” Cole v. Comm’r, 958 F.2d 288, 289 (9th Cir.1992); see also 26 U.S.C. § 7481(b). Because Parks’ case involved a disputed amount of less than $50,000 and he consented to its designation as a “small tax” case, we dismiss Parks’ appeal from the Tax Court’s decision. See 26 U.S.C. § 7463(a); Cole, 958 F.2d at 289-90.

DISMISSED.

This disposition is not…

2Cases cited1 opinion

  1. Earl G. And Donna R. Cole v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1992

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