Legal Opinion
Jackling v. Internal Revenue Service
District Court, D. New Hampshire
Decided November 23, 2004No. CIV. 03-263-JDPublishedCited by 4 opinions
1Opinion of the Court
ORDER
DICLERICO, District Judge.
The Internal Revenue Service moves to affirm its determination to proceed with the collection of trust fund recovery penalties assessed against plaintiff Christopher Jaekling pursuant to 26 U.S.C. § 6672(a). The IRS argues that this court lacks subject matter jurisdiction over Jackling’s pro se challenge to the determination because he failed to avail himself of the opportunity to challenge his liability for those penalties and, furthermore, that the IRS did not abuse its discretion.in deciding to proceed with their collection. Jaekling has not filed a response.…
2Cases cited13 opinions
- Eagle Eye Fishing Corporation v. United States Department of CommerceCourt of Appeals for the First Circuit · 1994
- Moore v. CommissionerUnited States Tax Court · 2000
- Jones v. CommissionerCourt of Appeals for the Fifth Circuit · 2003
- Behling v. Comm'rUnited States Tax Court · 2002
- Loofbourrow v. Commissioner of Internal Revenue ServiceDistrict Court, S.D. Texas · 2002
8 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Living Care Alternatives of Utica, Inc. v. United States of America, Internal Revenue ServiceCourt of Appeals for the Sixth Circuit · 2005
- Swain v. United States Department of Treasury (In Re Swain)United States Bankruptcy Court, E.D. Michigan · 2010
- Render v. Internal Revenue ServiceDistrict Court, E.D. Michigan · 2005
- Living Care v. USA/IRSCourt of Appeals for the Sixth Circuit · 2005