Legal Opinion
James J. Randazzo v. United States of America, Department of the Treasury, Internal Revenue Service
Court of Appeals for the Third Circuit
Decided December 27, 1984No. 84-3176PublishedCited by 14 opinions
1Opinion of the Court
OPINION OF THE COURT
2Per curiam
The controlling question for decision is whether we have jurisdiction to entertain an appeal from a judgment of the district court, 581 F.Supp. 1235 (Pa.1984), denying a request for attorney’s fees made in conjunction with judicial review of a termination or jeopardy assessment under the Internal Revenue Code. We hold that we have no jurisdiction.
The Allegheny County (Pennsylvania) police arrested the taxpayer, James J. Ran-dazzo, for the possession and sale of cocaine. A search of his house disclosed a safe containing over $50,000 in cash. Further investigation led to the…
3Cases cited1 opinion
- Randazzo v. United States Department of the Treasury Internal Revenue ServiceDistrict Court, W.D. Pennsylvania · 1984
4Cited by14 opinions
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- Donald E. Hiley and Ruth v. Hiley v. United StatesCourt of Appeals for the Seventh Circuit · 1986
- Zinniel v. CommissionerCourt of Appeals for the Seventh Circuit · 1989
- John C. Zinniel v. Commissioner Of Internal RevenueCourt of Appeals for the Seventh Circuit · 1989
- Erma Stites v. United StatesCourt of Appeals for the Ninth Circuit · 1992
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