Michael E. KOHN; Catherine K. Kohn, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee, 377 F. App'x 578

PER CURIAM. Michael Kohn and Catherine Kohn challenge the tax court’s decision, rendered after a bench trial, upholding the Internal Revenue Service’s Notice of Determination (NOD) related to the Kohns’ liabilities for tax year 2001. We review the tax court’s legal conclusions de novo, and its findings of act for clear error. See Campbell v. Comm’r, 164 F.3d 1140, 1142 (8th Cir.1999). Assuming without deciding that the tax court had authority under 26 U.S.C. § 6330(d)(1) to consider certain matters raised by the Kohns related to tax years prior to 2001, cf. Orum v.

Comm’r, 412 F.3d 819, 821-22 (7th Cir.2005), we affirm the tax court’s decision for the reasons stated in its memorandum and opinion. See 8th Cir. R. 47B. . The Honorable L. Paige Marvel, United States Tax Court Judge.