Legal Opinion
Vierow v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided December 16, 2005No. 05-70784Published
1Opinion of the Court
MEMORANDUM **
Michael E. Vierow appeals pro se the tax court’s decision sustaining the Commissioner of Internal Revenue’s (“Commissioner”) collection action related to tax years 1994, 1995, 1996, 1997, and 1998. We have jurisdiction pursuant to 26 U.S.C. § 7482. We review de novo the tax court’s conclusions of law and review for clear error findings of fact. Baizer v. Comm’r, 204 F.3d 1231, 1233-34 (9th Cir.2000). We affirm.
The tax court correctly concluded that the appeals officer did not abuse his discretion in verifying that all legal and administrative requirements had been met. See Nestor…
2Cases cited4 opinions
- Blaine P. Thompson v. United States Department of LaborCourt of Appeals for the Ninth Circuit · 1989
- Nestor v. Comm'rUnited States Tax Court · 2002
- Neil M. Baizer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
- Richard C. Hughes Joan C. Hughes v. United States of America Commissioner of Internal Revenue, Richard C. Hughes Joan C. Hughes v. Commissioner of Irs United States of America Steven R. High Lena High United Savings BankCourt of Appeals for the Ninth Circuit · 1992