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stating courts generally decline to consider arguments raised for the first time in reply briefs because in such cases, opposing parties are deprived of adequate opportunity to respond
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The panel unanimously finds this case suitable for decision without oral argument. See Fed. R.App. P. 34(a)(2).
NOT FOR PUBLICATION. (See Federal Rule of Appellate Procedure Rule 36-3)
Appeal from the United States District Court for the Southern District of California M. James Lorenz, District Judge, Presiding.
Page 613.
Before KOZINSKI and GOULD, Circuit Judges, and BREYER, District Judge.
Honorable Charles R. Breyer, United States District Judge for the Northern District of California, sitting by designation.
This disposition is not appropriate for publication and may not be cited to or by the courts of this circuit except as may be provided by 9th Cir. R. 36-3.
Husband and wife James and Shelley Boyce ("the Boyces") appeal the district court's order reducing to judgment the Boyces' unpaid tax assessments. The Boyces claim the district court erroneously applied res judicata (claim preclusion) to a tax court judgment determining the Boyces' tax liabilities and erroneously determined on summary judgment the amount of tax liability to be reduced to judgment. We affirm for the reasons stated by the district court judges in their thorough and well-reasoned written orders.
AFFIRMED.