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RANDAZZO v. UNITED STATES

No. 84-3176.

751 F.2d 145 (1984)

James J. RANDAZZO, Appellant v. UNITED STATES of America, Department of the Treasury, Internal Revenue Service, et al.

United States Court of Appeals, Third Circuit.

Decided December 27, 1984.

Attorney(s) appearing for the Case

David A. Goodman (argued), Pittsburgh, Pa., for appellant.

Michael L. Paup, Chief, Appellate Section, Glenn L. Archer, Jr., Asst. Atty. Gen., Gilbert S. Rothenberg, Laurie A. Snyder (argued), U.S. Dept. of Justice, Tax Division, Washington, D.C., for appellee; J. Alan Johnson, U.S. Atty., Pittsburgh, Pa., of counsel.

Before ALDISERT, Chief Judge, BECKER, Circuit Judge, and STERN, District Judge.

OPINION OF THE COURT

PER CURIAM.

The controlling question for decision is whether we have jurisdiction to entertain an appeal from a judgment of the district court, 581 F.Supp. 1235 (Pa.1984), denying a request for attorney's fees made in conjunction with judicial review of a termination or jeopardy assessment under the Internal Revenue Code. We hold that we have no jurisdiction.

The Allegheny County (Pennsylvania...

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