United States v. Joseph D. Meyer

GRUENDER, Circuit Judge.

Joseph Meyer failed to file timely federal income tax returns for tax years 2002 and 2009, and the Government levied tax assessments. Meyer maintains that those assessments are invalid because the Internal Revenue Service ("IRS") failed to follow Internal Revenue Code provisions requiring it to mail a notice of deficiency ("NOD" or "ninety-day letter") to him for each tax year before assessing deficiencies. The district court 1 granted the Government's motion for summary judgment and denied Meyer's cross motion for summary judgment. Meyer appeals both orders. We affirm.