Waring Park v. Internal Revenue Service District Director

34 F.3d 1073 74 A.F.T.R.2d 94 -5831 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Waring PARK, Plaintiff-Appellant, v. INTERNAL REVENUE SERVICE DISTRICT DIRECTOR, Defendant-Appellee. No. 93-35617. United States Court of Appeals, Ninth Circuit. Submitted Aug. 3, 1994. * Decided Aug. 9, 1994. Before: WALLACE, Chief Judge, HUG and RYMER, Circuit Judges. 1 MEMORANDUM ** 2 Waring Park appeals pro se the district court's dismissal of his action for lack of subject-matter jurisdiction and failure to state a claim upon which relief may be granted. Park sued the District Director and the Regional Director of the Internal Revenue Service (IRS) for (1) damages allegedly resulting from defendants' actions in assessing and collecting tax deficiencies owed by Park for the tax years 1984, 1985, and 1986, and (2) a refund of funds the IRS had levied upon to satisfy those deficiencies. We have jurisdiction under 28 U.S.C. Sec. 1291 . We review de novo, Kruso v. International Tel. &…