Michael L. Montalvo v. United States of America Calvin Esselstorm, Director
Opinion
Opinion
978 F.2d 715 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Michael L. MONTALVO, Petitioner-Appellant, v. UNITED STATES of America; Calvin Esselstorm, Director, Respondents-Appellees. No. 91-56508. United States Court of Appeals, Ninth Circuit. Submitted Oct. 22, 1992. * Decided Oct. 28, 1992. Before SNEED, BEEZER and WIGGINS, Circuit Judges. 1 MEMORANDUM ** 2 Michael Montalvo appeals pro se the district court's dismissal of his action for lack of jurisdiction. In his action, Montalvo sought declaratory and injunctive relief regarding a jeopardy assessment of his 1984 federal tax liability. We have jurisdiction pursuant to 28 U.S.C. § 1291 . We review de novo a district court's dismissal for lack of subject matter jurisdiction, Kruso v. International Tel. & Tel. Corp., 872 F.2d 1416 , 1421 (9th Cir.1989), cert. denied, 496 U.S. 937 (1990), and we affirm. 3 Montalvo filed a complaint against the United States seeking declaratory and injunctive relief. He alleged…