111664P.pdf   04/11/2012  Thomas Gillum  v.  CIR
   U.S. Court of Appeals Case No:  11-1664
   Tax Court, Internal Revenue Service   
   [PUBLISHED] [Smith, Author, with Colloton and Gruender, Circuit Judges]
   Appeal from the United States Tax Court. Tax court did not err in
   finding taxpayer was not denied a fair collection due process hearing as
   the IRS settlement officer confirmed that the administrative record
   provided the tax court was complete and that the facts he relied upon in
   making his determinations were part of the administrative record; even if
   the IRS settlement officer relied on documents outside the administrative
   record, the error was harmless; Tax Court did not err in finding it did not
   have jurisdiction over taxpayer's purported alter egos and nominees as
   they were not parties to the proceeding. Judge Colloton, dissenting.