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PAGONIS v. U.S.

No. 08-2798.

575 F.3d 809 (2009)

Elaine T. PAGONIS, Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: August 11, 2009.

Attorney(s) appearing for the Case

Daniel W. Schermer, argued, Minneapolis, MN, for appellant.

Teresa E. McLaughlin, argued, Gretchen M. Wolfinger, USDOJ-Tax Division, Washington, DC, for appellee.

Before WOLLMAN, BRIGHT, and COLLOTON, Circuit Judges.

COLLOTON, Circuit Judge.

Elaine T. Pagonis brought this action against the United States seeking relief in a tax dispute with the government. The district court1 dismissed the case for lack of subject matter jurisdiction. We affirm.

I.

The Internal Revenue Service ("IRS") conducted a civil audit of Pagonis and issued a notice of deficiency on June 15, 1998. The notice stated that Pagonis owed additional income taxes and...

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