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No. 96-1147MN _____________

Laxman S. Sundae, * * Appellant, * * Appeal from the United States v. * District Court for the District * of Minnesota. United States of America; * Internal Revenue Service, * [UNPUBLISHED] * Appellees. * _____________

Submitted: November 21, 1996

Filed: November 27, 1996 _____________

Before FAGG, WOLLMAN, and HANSEN, Circuit Judges. _____________

PER CURIAM.

Laxman S. Sundae appeals the district court's grant of summary judgment in favor of the Government denying Sundae's claim for a refund of federal income taxes for the years 1983 and 1984.

After a careful review of the record, we conclude the district court properly granted the Government's motion. Because this case is highly fact-specific, an extended opinion would have no precedential value. Having carefully considered all of Sundae's contentions and finding them to be without merit, we affirm the district court without further discussion. See 8th Cir. R. 47B.

A true copy.

Attest:

CLERK, U.S. COURT OF APPEALS, EIGHTH CIRCUIT.