Kailing

MEMORANDUM **

Melville and Letitia Turner appeal pro se the district court’s deficiency judgment for the United States in an action brought by the United States to reduce the Turners’ income tax assessments to judgment, to set aside a transfer of certain real property, and to foreclose federal tax liens against the real property in satisfaction of the tax debt. We have jurisdiction under 28 U.S.C. § 1291 . We review de novo the existence of subject matter jurisdiction, United States v. Peninsula Communications, Inc., 287 F.3d 832, 836 (9th Cir. 2002), and review for abuse of discretion the denial of a motion for reconsideration, Kona Enters., Inc., v. Estate of Bishop, 229 F.3d 877 , 883 (9th Cir.2000). We affirm.

The district court did not err when, interpreting the Turners’ motion to vacate as a motion to dismiss for lack of subject matter jurisdiction, it denied the motion. See 26 U.S.C. § 7402 (district courts at the instance of the United States have jurisdiction to issue orders and make judgments for the enforcement of the internal revenue laws); 28 U.S.C. § 1340 (district courts have jurisdiction over internal revenue matters); Boynton v. United States, 566 F.2d 50, 52…