Martin Schachter v. United States of America, Marcia Karp, Administrator of the Estate of David S. Karp v. United States

77 F.3d 490 77 A.F.T.R.2d 96 -858, 96-1 USTC P 50,152 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Martin SCHACHTER, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee. Marcia KARP, Administrator of the Estate of David S. Karp, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee. Nos. 94-16726, 94-16788. United States Court of Appeals, Ninth Circuit. Argued and Submitted Jan. 11, 1996. Decided Feb. 8, 1996. Before: ALDISERT, * SCHROEDER and TROTT, Circuit Judges. 1 MEMORANDUM ** 2 Martin Schachter and Marcia Karp appeal from the district court's ruling at summary judgment that an Internal Revenue Service agent did not unlawfully disclose tax return information to various individuals. 3 The district court had jurisdiction under 26 U.S.C. § 7431 (a)(1). We have jurisdiction pursuant to 28 U.S.C. § 1291 . Appeal was timely filed under Rule 4(a), Federal Rules of Appellate Procedure. We review de novo the district court's…