Jimmy Jackson LITTLE, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee, 219 F. App'x 329

PER CURIAM: Jimmy Jackson Little appeals the tax court’s orders sustaining the Commissioner’s collection determination with respect to his 1998, 1999, 2000, and 2001 federal income tax liability and imposing a penalty under 26 U.S.C. § 6673(a) (2000). We have reviewed the record and find no reversible error. Accordingly, we dismiss the appeal for the reasons stated by the tax court. Little v. Comm’r of Internal Revenue, No. 05-9013-L (U.S.T.C. Feb. 15, 2006). We deny the Commissioner’s motion for sanctions without prejudice.

We deny Little’s motion to proceed in forma pauperis and dispense with oral argument because the facts and legal contentions are adequately presented in the materials before the court and argument would not aid the decisional process. DISMISSED. The Commissioner is free to seek sanctions if Little files another appeal in this court raising similar arguments.