Legal Opinion
Frank A. Littriello v. United States of America and United States Department of Treasury
Court of Appeals for the Sixth Circuit
Decided April 13, 2007No. 05-6494PublishedCited by 38 opinions
1Opinion of the Court
OPINION
MARTHA CRAIG DAUGHTREY, Circuit Judge.
In this appeal from a grant of summary judgment to the government, we are presented with a case of first impression regarding the validity of the Treasury Department’s so-called “check-the-box” regulations, 26 C.F.R. §§ 301.7701-1 to 301.7701-3, promulgated in 1996 to simplify the classification of business entities for tax purposes.
The plaintiff, Frank Littriello, was the sole owner of several Kentucky limited liability companies (LLCs), the operation of which resulted in unpaid federal employment taxes totaling $1,077,000. Because Littriello was…
2Cases cited10 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Barnhart v. ThomasSupreme Court of the United States · 2003
- National Cable & Telecommunications Assn. v. Brand X Internet ServicesSupreme Court of the United States · 2005
- Commodity Futures Trading Commission v. SchorSupreme Court of the United States · 1986
- Morrissey v. CommissionerSupreme Court of the United States · 1935
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3Cited by38 opinions
- Santomenno Ex Rel. John Hancock Trust v. John Hancock Life Insurance Co. (U.S.A)Court of Appeals for the Third Circuit · 2014
- City of Cleveland v. OhioCourt of Appeals for the Sixth Circuit · 2007
- Wright v. Experian Information Solutions, Inc.Court of Appeals for the Tenth Circuit · 2015
- Sean P. McNamee v. Department of the Treasury, Internal Revenue Service, Docket No. 05-6151-CvCourt of Appeals for the Second Circuit · 2007
- Little v. CookeSupreme Court of Virginia · 2007
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