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JEROME MIRZA & ASSOCIATES, LTD. v. U.S.

No. 88-2774.

882 F.2d 229 (1989)

JEROME MIRZA & ASSOCIATES, LTD., an Illinois corporation, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided August 10, 1989.

Rehearing and Rehearing Denied October 25, 1989.

Attorney(s) appearing for the Case

Dean B. Rhoads and Edward F. Sutkowski, Sutkowski & Washkuhn, Peoria, Ill., for Jerome Mirza & Associates, Ltd., plaintiff-appellant.

Jeffrey N. Kaplan, Dept. of Justice, Tax Div., Washington, D.C., John A. Mehlick, Asst. U.S. Atty., Office of the U.S. Atty., Springfield, Ill., Gary R. Allen, William S. Rose, Jr., Asst. Atty. Gen., and Jonathan S. Cohen, and Michael Roach, Dept. of Justice, Tax Div., Appellate Section, Washington, D.C., for the U.S.

Before COFFEY, FLAUM and RIPPLE, Circuit Judges.

Rehearing and Rehearing En Banc Denied October 25, 1989.

FLAUM, Circuit Judge.

Jerome Mirza & Associates appeals from a district court decision dismissing its claim for a refund of federal income taxes under 28 U.S.C. § 1346(a)(1). For the reasons discussed below, we affirm.

I.

The taxpayer Jerome Mirza & Associates is a professional corporation engaged in the business of providing legal services. In 1980, the taxpayer established...

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