Fourth Circuit Affirms Decision Upholding IRS Collection Action

CONRAD PRENTISS BURNETT, JR.,
Petitioner-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent-Appellee.

UNPUBLISHED

UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT

Appeal from the United States Tax Court
(Tax Ct. No. 007767-17L)

Submitted: August 29, 2019

Decided: September 6, 2019

Before MOTZ, QUATTLEBAUM, and RUSHING, Circuit Judges.

Affirmed by unpublished per curiam opinion.

Conrad Prentiss Burnett, Jr., Appellant Pro Se. Paul Andrew Allulis, Clint Aaron Carpenter, Ellen Page DelSole, Tax Division, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee.

Unpublished opinions are not binding precedent in this circuit.

PER CURIAM:

Conrad Prentiss Burnett, Jr., appeals from the tax court's order granting summary judgment to the Commissioner on Burnett's petition challenging the Commissioner's determination to proceed with collection action. We have reviewed the record and find no reversible error. Accordingly, we affirm for the reasons stated by the tax court. Burnett v. Comm'r, Tax Ct. No. 007767-17L (T.C. Dec. 19, 2018). We deny Burnett's “Motion to Resolve the Conflict in the Circuit Courts,” and his motion for oral argument because the facts and legal contentions are adequately presented in the materials before this court and argument would not aid the decisional process.

AFFIRMED