Opinion
Because the panel unanimously finds this case suitable for decision without oral argument, see Fed. R.App. P. 34(a)(2), Hodgson's request for oral argument is denied.
NOT FOR PUBLICATION. (See Federal Rule of Appellate Procedure Rule 36-3)
Taxpayer appealed pro se from decision of the United States Tax Court sustaining Commissioner of Internal Revenue's collection action of federal income tax due. The Court of Appeals held that appeals officer did not abuse his discretion by relying on Certificates of Assessments and Payments.
Affirmed.
Appeal from the United States Tax Court.
Page 572.
Before HAWKINS, TASHIMA, and GOULD, Circuit Judges.
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.
LaVonne Allen Hodgson appeals pro se from a decision of the tax court sustaining the Commissioner of Internal Revenue's collection action of federal income tax due for 1994. We have jurisdiction pursuant to 26 U.S.C. § 7482(a), and we affirm.
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). The tax court did not err in concluding that the appeals officer did not abuse his discretion by relying on Certificates of Assessments and Payments to determine the validity of the underlying assessment of tax deficiency, see Koff v. United States, 3 F.3d 1297, 1298 (9th Cir.1993) (per curiam), and that the requisite notices were made, see Hansen v. United States, 7 F.3d 137, 138 (9th Cir.1993) (per curiam).
AFFIRMED.