
    SYNERGY STAFFING, INC., fka Personnel Connection, Inc., Plaintiff—Appellant, v. UNITED STATES INTERNAL REVENUE SERVICE, Defendant—Appellee.
    No. 03-55968.
    United States Court of Appeals, Ninth Circuit.
    Argued and Submitted June 6, 2005.
    Decided June 10, 2005.
    Andrew M. Rosenfeld, Esq., Andrew M. Rosenfeld Law Offices, Torrance, CA, Karen D. Utiger, U.S. Department of Justice, Washington, DC, Plaintiff-Appellant.
    Darwin Thomas, Esq., Office of the U.S. Attorney, Los Angeles, CA, Annette M. Wietecha, Esq., Bruce R. Ellisen, U.S. Department of Justice, Washington, DC, for Defendant-Appellee.
    Before: TROTT, W. FLETCHER, Circuit Judges, and RESTANI, Judge.
    
      
       The Honorable Jane A. Restani, Chief Judge, United States Court of International Trade, sitting by designation.
    
   MEMORANDUM

Synergy Staffing appeals the district court’s grant of summary judgment to the Internal Revenue Service on Synergy’s claim that it is entitled to a tax refund for the year 1997. For the reasons stated by the district court, we AFFIRM.

AFFIRMED. 
      
       This disposition is not appropriate for publication and may not be cited to or by the courts of this circuit except as provided by Ninth Circuit Rule 36-3.
     