Legal Opinion

Sean P. McNamee v. Department of the Treasury, Internal Revenue Service, Docket No. 05-6151-Cv

Court of Appeals for the Second Circuit

Decided May 23, 2007No. 100PublishedCited by 49 opinions

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…

2Cases cited9 opinions

  1. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  2. United States v. Mead Corp.Supreme Court of the United States · 2001
  3. National Cable & Telecommunications Assn. v. Brand X Internet ServicesSupreme Court of the United States · 2005
  4. Commodity Futures Trading Commission v. SchorSupreme Court of the United States · 1986
  5. National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979

4 more not listed; retrieve them via the Exa API.

3Cited by49 opinions

  1. United States v. HagermanCourt of Appeals for the Seventh Circuit · 2008
  2. Estate of Landers Ex Rel. Landers v. LeavittCourt of Appeals for the Second Circuit · 2008
  3. Swallows Holding, Ltd. v. CommissionerCourt of Appeals for the Third Circuit · 2008
  4. City of New York v. Permanent Mission of India to the United NationsCourt of Appeals for the Second Circuit · 2010
  5. Pierre v. Comm'rUnited States Tax Court · 2009

44 more not listed; retrieve them via the Exa API.

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