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COHN v. U.S.

No. 985, Docket 88-6320.

872 F.2d 533 (1989)

J. Bradley COHN and Elizabeth R. Cohn, on behalf of themselves and all others similarly situated, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Second Circuit.

Decided April 13, 1989.

Attorney(s) appearing for the Case

Michael Bray, New York City (J. Bradley Cohn, of counsel), for plaintiffs-appellants.

Gabriel W. Gorenstein, Asst. U.S. Atty., for S.D.N.Y. (Benito Romano, U.S. Atty. and Nancy Kilson, Asst. U.S. Atty., for S.D.N.Y., New York City, of counsel), for defendant-appellee.

Before PRATT and MINER, Circuit Judges.

PER CURIAM:

J. Bradley Cohn and Elizabeth R. Cohn appeal from a judgment of the United States District Court for the Southern District of New York, John E. Sprizzo, Judge, awarding the government judgment on the pleadings and denying the Cohns' motion for class certification. The Cohns dispute the manner in which the Internal Revenue Service ("IRS") calculates interest on tax deficiencies. We affirm because the statutory language and legislative history of...

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