USA v. Carlos D. Dickerson

United States Court of Appeals
FOR THE EIGHTH CIRCUIT
___________
No. 03-3389
___________
Dale L. Oyer, Transferee, *
*
Appellant, *
*
v. *
*
Commissioner of Internal *
Revenue Service, *
*
Appellee. *
___________ Appeals from the United States
Tax Court.
No. 03-3390
___________ [UNPUBLISHED]
Acme Leasing Trust, Transferee, *
*
Appellant, *
*
v. *
*
Commissioner of Internal *
Revenue Service, *
*
Appellee. *

-- 1 of 3 --

-2-
___________
No. 03-3391
___________
ABC Seamless Trust, Transferee, *
*
Appellant, *
*
v. *
*
Commissioner of Internal *
Revenue Service, *
*
Appellee. *
___________
No. 03-3392
___________
Shirley J. Oyer, Transferee, *
*
Appellant, *
*
v. *
*
Commissioner of Internal *
Revenue Service, *
*
Appellee. *

-- 2 of 3 --

-3-
___________
Submitted: April 16, 2004
Filed: May 20, 2004
___________
Before MORRIS SHEPPARD ARNOLD, MAGILL, and MURPHY, Circuit Judges.
___________
PER CURIAM.
This is an appeal from the Tax Court's order granting summary judgment in
favor of the Internal Revenue Service in taxpayers' suit challenging the IRS's
determination that they were liable as transferees for taxes in the amount of
approximately $90,000. The Tax Court held, inter alia, that the doctrine of res
judicata barred taxpayers from contesting the amount owed because the court had
previously entered stipulated decisions against taxpayers that determined the taxes
that are the subject of the dispute here.
We have carefully examined the record and conclude that the Tax Court
correctly applied the doctrine of res judicata in this case. We therefore affirm on the
basis of its well-reasoned decision. See 8th Cir. R. 47B.
______________________________

-- 3 of 3 --