Legal Opinion

AllGlass Systems, Inc. v. Commissioner

District Court, E.D. Pennsylvania

Decided August 17, 2004No. Civ.A. 03-4772PublishedCited by 1 opinion

1Opinion of the Court

MEMORANDUM

ROBRENO, District Judge.

Plaintiffs, AllGlass Systems, Inc., East Coast Fabricators, LLC, and ASI Southeast, LLC (collectively “taxpayers”) filed this action, seeking review of the Internal Review Service’s (“IRS”) issuance of three Notices of Determination Concerning Collection Action under Internal Revenue Code (“IRC”) Sections 6320 and/or 6330. There is no dispute as to taxpayers’ liability to the IRS for employment taxes not paid in 2000 and 2001. Taxpayers allege that the IRS issued Notices of Levy without properly providing a Collection Due Process (“CDP”) hearing as required…

2Cases cited8 opinions

Motor Vehicle Mfrs. Assn. of United States, Inc. v. State Farm Mut. Automobile Ins. Co.Supreme Court of the United States · 1983
Citizens to Preserve Overton Park, Inc. v. VolpeSupreme Court of the United States · 1971
Califano v. SandersSupreme Court of the United States · 1977
Roman v. Comm'rUnited States Tax Court · 2004
Loofbourrow v. Commissioner of Internal Revenue ServiceDistrict Court, S.D. Texas · 2002

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3Cited by1 opinion

Marc Perkel v. CommissionerUnited States Tax Court · 2007