Jack Randell v. United States

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. Statutory and Regulatory Framework

Before laying out the facts of this dispute, it will be helpful to set forth briefly the statutory and regulatory context…