Patricia Hyde v. CIR

Filing

PER CURIAM OPINION FILED - THE COURT: ROGER L. WOLLMAN, MICHAEL J. MELLOY and LAVENSKI R. SMITH (UNPUBLISHED) [3927694] [12-1179]

United States Court of Appeals
FOR THE EIGHTH CIRCUIT

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No. 12-1179
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Patricia Louise Hyde,

*
*
Petitioner,
*
* Appeal from the
v.
* United States Tax Court.
*
Commissioner of Internal Revenue,
* [UNPUBLISHED]
*
Respondent.
*
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Submitted: June 28, 2012
Filed: July 2, 2012
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Before WOLLMAN, MELLOY, and SMITH, Circuit Judges.
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PER CURIAM.
Patricia Louise Hyde appeals the tax court’s1 decision upholding the
Commissioner of Internal Revenue’s determination that she was liable for an income
tax deficiency and additions for tax year 2006, assessing her liabilities, and imposing
a 26 U.S.C. § 6673 penalty for asserting frivolous and groundless arguments. She
also appeals the tax court’s denial of her motion, under Tax Court Rule 162, to vacate
its decision.

1

The Honorable David Laro, United States Tax Court Judge.

Appellate Case: 12-1179

Page: 1

Date Filed: 07/02/2012 Entry ID: 3927694

After careful review, we agree with the tax court’s decision upholding Hyde’s
2006 liabilities. See Campbell v. Comm’r, 164 F.3d 1140, 1142 (8th Cir. 1999) (tax
court’s findings of fact are reviewed for clear error, and its legal conclusions are
reviewed de novo). We also find no abuse of discretion in the tax court’s imposition
of the section 6673 penalty, see May v. Comm’r, 752 F.2d 1301, 1304-05 (8th Cir.
1985) (standard of review), or in the tax court’s denial of her Rule 162 motion.
Accordingly, we affirm. See 8th Cir. R. 47B.
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Appellate Case: 12-1179

Page: 2

Date Filed: 07/02/2012 Entry ID: 3927694