Norman Katz Suzanne L. Hill v. United States of America Commissioner of Internal Revenue

87 F.3d 1320 78 A.F.T.R.2d 96 -5206 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Norman KATZ; Suzanne L. Hill, Plaintiffs-Appellants, v. UNITED STATES of America; Commissioner of Internal Revenue, Defendants-Appellees. No. 95-55819. United States Court of Appeals, Ninth Circuit. Submitted June 11, 1996. * Decided June 19, 1996. Before: CANBY, NOONAN, and LEAVY, Circuit Judges. 1 MEMORANDUM ** 2 Norman Katz appeals pro se the district court's dismissal of his action against the United States and the Commissioner of Internal Revenue ("Commissioner") seeking a "set-off" in the amount of $2,500 against an asserted deficiency in his federal income taxes for the tax year 1981. 1 Katz alleged that the United States failed to prosecute the promoters of a tax shelter in which he invested despite evidence that these individuals engaged in fraud. Katz claims that the government's failure to prosecute these individuals cost him the amount of money that he invested in the scheme. We…