Sean P. McNamee v. Department of the Treasury, Internal Revenue Service, Docket No. 05-6151-Cv
Court of Appeals for the Second Circuit
1Opinion of the Court
KEARSE, Circuit Judge.
Plaintiff pro se Sean P. McNamee, the single-member owner of a now-defunct limited liability company (or “LLC”) formed under Connecticut law, appeals from a judgment of the United States District Court for the District of Connecticut, Christopher F. Droney, Judge, rejecting his challenge to a determination by the Internal Revenue Service (“IRS”) under Treasury Regulations §§ 301.7701-2 and 301.7701-3, 26 C.F.R. §§ 301.7701-2 and 301.7701-3, that, because of his failure to exercise his option to have his LLC treated as a corporation, McNamee was person ally liable for the…
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