James Rochowicz Maria Rochowicz v. Internal Revenue Service

53 F.3d 339 75 A.F.T.R.2d 95 -2189 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. James ROCHOWICZ; Maria Rochowicz, Plaintiffs-Appellants, v. INTERNAL REVENUE SERVICE, Defendant-Appellee. No. 93-56446. United States Court of Appeals, Ninth Circuit. Argued and Submitted Feb. 9, 1995. Decided May 2, 1995. 1 Before: BEEZER and NOONAN, Circuit Judges, and EZRA, District Judge. * 2 MEMORANDUM ** 3 James and Maria Rochowicz appeal pro se the district court's grant of summary judgment in favor of the United States. The Rochowiczs filed this action alleging that the Internal Revenue Service ("IRS") erroneously assessed tax deficiencies and that the IRS used illegal procedures in attempting to collect these taxes. The Rochowiczs seek to have the taxes in question abated, to have the IRS enjoined from levying on their assets, and to receive $100,000 in damages. 4 The district court had jurisdiction over some of these claims pursuant to 28 U.S.C. Secs. 1340 and 2410. Whether the…