Western Management, Inc. v. Commissioner

MEMORANDUM *

Appellant Western Management, Inc. (“Western”) appeals (1) the Tax Court’s refusal to review issues outside the remand order; and (2) the Tax Court’s denial of Western’s request for attorney’s fees. We affirm.

Western appeals the Tax Court’s denial of its claims on remand from this court that its outstanding Federal Insurance Contributions Act tax liability and the 26 U.S.C. §§ 6656 and 6662(a) penalties and interest assigned to it should be abated. We have “repeatedly held, in both civil and criminal cases, that a district court is limited by this court’s remand in situations…