                 United States Court of Appeals
                            For the Eighth Circuit
                        ___________________________

                                No. 14-2382
                        ___________________________

                               James A. Widtfeldt

                            lllllllllllllllllllllAppellant

                                          v.

                       Commissioner of Internal Revenue

                           lllllllllllllllllllllRespondent
                        ___________________________

                                No. 14-2444
                        ___________________________

Estate of Gusteva Widtfeldt, Deceased, James A. Widtfeldt, Personal Representative

                             llllllllllllllllllllAppellant

                                          v.

                       Commissioner of Internal Revenue

                            lllllllllllllllllllllAppellee
                        ___________________________

                                No. 15-2166
                        ___________________________

  Estate of Gusteva E. Widtfeldt, Deceased, James Widtfeldt, Statutory Executor

                            lllllllllllllllllllllPetitioner
                                            v.
                         Commissioner of Internal Revenue

                              lllllllllllllllllllllRespondent
                                      ____________

                     Appeals from the United States Tax Court
                                 ____________

                              Submitted: March 7, 2016
                               Filed: March 11, 2016
                                   [Unpublished]
                                   ____________

Before LOKEN, MURPHY, and BYE, Circuit Judges.
                           ____________

PER CURIAM.

       In these consolidated appeals--two of which arise from actions that were
dismissed as duplicating the first action--James Widtfeldt appeals the tax court’s
grant of summary judgment to the Commissioner of Internal Revenue in a collection
due process case. Following careful de novo review, we agree with the
Commissioner that Widtfeldt was not entitled to re-litigate the tax liability of his
deceased mother’s estate, and Widtfeldt has identified no basis for reversal. See 26
U.S.C. § 6330; Nestle Purina Petcare Co. v. Comm’r, 594 F.3d 968, 970 (8th Cir.
2010) (de novo review of tax court’s grant of summary judgment); Widtfeldt v.
Comm’r, 449 Fed. Appx. 561 (8th Cir. Jan. 9, 2012) (unpublished per curiam). We
also conclude that the tax court did not abuse its discretion in dismissing the duplicate
actions. The rulings of the tax court are affirmed, see 8th Cir. R. 47B, and the
Commissioner’s motion is denied as moot.
                        ______________________________



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