SAM E. SCOTT, Petitioner-Appellant v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee, United States Court of Appeals Fifth Circuit, No. 07-60573 Summary Calendar, Filed January 23, 2008

SAM E. SCOTT, Petitioner-Appellant v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee

United States Court of Appeals Fifth Circuit

No. 07-60573 Summary Calendar

Filed January 23, 2008

Unpublished Opinion

Appeal from the United States Tax Court

(2537-05L)

Before WIENER, GARZA, and BENAVIDES, Circuit Judges.

PER CURIAM: ^*

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* ═ Pursuant to 5TH CIR. R. 47.5, the court has determined that this opinion should not be published and is not precedent except under the limited circumstances set forth in 5TH CIR. R. 47.5.4.

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Petitioner-Appellant Sam E. Scott has managed to stall, delay, avoid, and otherwise keep from paying his 1991 income tax deficiency that was determined on its merits by the United States Tax Court in June, 1998 and affirmed by this court in June, 1999. ¹ Scott is again before us on appeal from the United States Tax Court, this time seeking reversal of that Court's Memorandum Opinion filed April 17, 2007, holding that the Commissioner's pursuit of collection by filing notices of federal tax liens was not an abuse of discretion. We affirm.

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¹ ═ See Scott v. Commissioner, 182 F.3d 915 (5th Cir. 1999).

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We have carefully reviewed the record on appeal, the briefs of the parties, and the applicable law; and our review satisfies us completely that the United States Tax Court correctly determined that the Commissioner did not abuse his discretion in any way, shape, or form in endeavoring to collect taxes, interest, etc. previously determined to be due and owing by Scott. Specifically, the Commissioner did not abuse his discretion in the filing of the above-said notices of federal tax liens. For essentially the reasons set forth in the aforesaid Memorandum Opinion, the judgment appealed from is, in all respects,

AFFIRMED.

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