UNPUBLISHED
UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
No. 99-2232
RICHARD E. SNYDER; MARION B. SNYDER,
Petitioners - Appellants,
versus
COMMISSIONER OF INTERNAL REVENUE,
Respondent - Appellee.
Appeal from the United States Tax Court. (Tax Ct. No. 97-24568)
Submitted: April 13, 2000 Decided: April 19, 2000
Before WIDENER and WILKINS, Circuit Judges, and HAMILTON, Senior
Circuit Judge.
Affirmed by unpublished per curiam opinion.
Richard E. Snyder, Marion B. Snyder, Appellants Pro Se. Frank
Phillip Cihlar, Kenneth L. Greene, UNITED STATES DEPARTMENT OF
JUSTICE, Washington, D.C., for Appellee.
Unpublished opinions are not binding precedent in this circuit.
See Local Rule 36(c).
PER CURIAM:
Richard E. and Marion B. Snyder appeal from the tax court’s
order denying their motion for an injunction to remove a lien and
to order the Internal Revenue Service to refrain from collection
activity with respect to the amount of taxes due under a correction
notice. We have reviewed the record and the tax court’s order and
find no reversible error. Because the summary assessment for which
the lien was obtained concerned a deficiency that was not part of
the deficiency amount challenged in the Snyders’ petition pending
in the tax court, the tax court lacked jurisdiction to issue the
requested injunction. See 26 U.S.C.A. § 6213(a), (b)(1), (d)(2)(D)
(West Supp. 1999). Accordingly, we affirm. We dispense with oral
argument because the facts and legal contentions are adequately
presented in the materials before the court and argument would not
aid the decisional process.
AFFIRMED
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