Silver v. Smith

SUMMARY ORDER

Plaintiff-Appellant Glen Silver, proceeding pro se, sued Defendants-Appellees Michael Smith and Carl Garkowski, employees of the Internal Revenue Service (“IRS”), challenging two tax hens filed against him by the IRS, the first for unpaid income taxes assessed for tax years 1995 and 1996, and the second for the assessment of a frivolous return penalty. Silver now appeals a decision and order of the district court that (1) substituted the United States as the party defendant, dismissing the complaint against Smith and Garkowski; (2) granted summary judgment in favor of defendant…