Ioane v. Commissioner of Internal Revenue ( 2011 )

FILED
NOT FOR PUBLICATION MAR 04 2011
MOLLY C. DWYER, CLERK
UNITED STATES COURT OF APPEALS U .S. C O U R T OF APPE ALS
FOR THE NINTH CIRCUIT
MICHAEL IOANE, No. 09-70708
Petitioner - Appellant, Tax Ct. No. 19292-07L
v.
MEMORANDUM *
COMMISSIONER OF INTERNAL
REVENUE,
Respondent - Appellee.
Appeal from a Decision of the
United States Tax Court
Submitted February 15, 2011 **
Before: CANBY, FERNANDEZ, and M. SMITH, Circuit Judges.
Michael Ioane appeals pro se from the tax court’s order dismissing his
petition contesting the Commissioner of Internal Revenue’s Notice of
Determination concerning income tax liabilities for tax years 1998 through 2002.
*
This disposition is not appropriate for publication and is not precedent
except as provided by Ninth Circuit Rule 36-3.
**
The panel unanimously concludes this case is suitable for decision
without oral argument. See Fed. R. App. P. 34(a)(2).
We have jurisdiction under 26 U.S.C. § 7482(a)(1). We review de novo. Suter v.
Goedert, 504 F.3d 982, 985 (9th Cir. 2007). We affirm.
The tax court properly dismissed Ioane’s petition on the ground of mootness,
because there was “‘no effective relief remaining for [the] court to provide’” after
the Internal Revenue Service rescinded the notice of intent to levy and withdrew
the tax liens. Id. at 986 (citation omitted).
Ioane’s remaining contentions are unpersuasive.
AFFIRMED.
2 09-70708