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RANDELL v. U.S.

No. 1097, Docket 94-6220.

64 F.3d 101 (1995)

Jack RANDELL, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Second Circuit.

Decided August 28, 1995.

Attorney(s) appearing for the Case

Jared J. Scharf, White Plains, NY, for plaintiff-appellant.

Deborah Y. Yeoh, Asst. U.S. Atty., New York City (Mary Jo White, U.S. Atty., Nancy G. Milburn, Asst. U.S. Atty., S.D.N.Y., New York City, of counsel), for defendant-appellee.

Before: MESKILL, CARDAMONE, and ALTIMARI, Circuit Judges.

CARDAMONE, Circuit Judge:

This is an appeal in a tax case. Plaintiff Jack Randell brought suit in the United States District Court for the Southern District of New York (Goettel, J.) seeking to enjoin assessment of deficiencies made by the Internal Revenue Service (IRS) based on his distributive share of income from two partnerships. The district court granted summary judgment to the government and plaintiff appeals. We affirm.

BACKGROUND

A.

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