Dean Allen Steeves v. United States Internal Revenue Service

NOT FOR PUBLICATION
UNITED STATES COURT OF APPEALS
FOR THE NINTH CIRCUIT
DEAN ALLEN STEEVES,
Plaintiff-Appellant,
v.
UNITED STATES INTERNAL REVENUE
SERVICE,
Defendant-Appellee.
No. 22-56170
D.C. No. 3:22-cv-00838-WQH-DDL
MEMORANDUM*
Appeal from the United States District Court
for the Southern District of California
William Q. Hayes, District Judge, Presiding
Submitted March 26, 2024**
Before: TASHIMA, SILVERMAN, and KOH, Circuit Judges.
Dean Allen Steeves appeals pro se from the district court’s order dismissing
for lack of subject matter jurisdiction his action seeking to void notices of
deficiency issued by the Internal Revenue Service (“IRS”). We have jurisdiction
under 28 U.S.C. § 1291. We review de novo. Dexter v. Colvin, 731 F.3d 977, 980
* 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).
FILED
MAR 29 2024
MOLLY C. DWYER, CLERK
U.S. COURT OF APPEALS

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2 22-56170
(9th Cir. 2013). We affirm.
The district court properly dismissed Steeves’s action as barred by the Anti-
Injunction Act (“the Act”) because it is an attempt to restrain the IRS’s tax
assessment and collection activities, and no exception applies. See 26 U.S.C.
§ 7421(a) (listing statutory exceptions); Elias v. Connett, 908 F.2d 521, 523, 525
(9th Cir. 1990) (explaining that the district court “must dismiss for lack of subject
matter jurisdiction any suit that does not fall within one of the exceptions to the
Act” and setting forth limited judicial exception).
We do not consider arguments and allegations raised for the first time on
appeal. See Padgett v. Wright, 587 F.3d 983, 985 n.2 (9th Cir. 2009).
All pending motions and requests are denied.
AFFIRMED.

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