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ARMSTRONG v. UNITED STATES

No. 83-6356.

759 F.2d 1378 (1985)

Garrison R. ARMSTRONG, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided May 7, 1985.

Attorney(s) appearing for the Case

Lawrence S. Branton, San Diego, Cal., for plaintiff-appellant.

Carleton Powell, Washington, D.C., for defendant-appellee.

Before ELY, FLETCHER, and REINHARDT, Circuit Judges.

FLETCHER, Circuit Judge:

Garrison R. Armstrong appeals from the district court's order dismissing his tax refund action. Armstrong contends that Congress violated the origination clause of the Constitution, U.S. Const. art. I, § 7, cl. 1, when it passed the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub.L. No. 97-248, 96 Stat. 324 (1982), and therefore, TEFRA is invalid. The district court rejected his claim, and we affirm.

I.

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