Legal Opinion
Johnston v. Commissioner
Court of Appeals for the Ninth Circuit
Decided November 10, 2005No. 05-70209PublishedCited by 3 opinions
1Opinion of the Court
MEMORANDUM **
Petitioner Larry Johnston appeals pro se from the Tax Court’s summary judgment in favor of the Commissioner of Internal Revenue (“Commissioner”) in his action contesting deficiencies for tax years 1993 to 1997. We have jurisdiction pursuant to 26 U.S.C. § 7482. We review de novo, see Talley Indus. Inc. v. Comm’r, 116 F.3d 382, 385 (9th Cir.1997), and we affirm.
Johnston’s primary contention on appeal is that his case should be remanded for a second collection due process hearing so that he may record the hearing. Although a petitioner is entitled to record a collection due process…
2Cases cited4 opinions
- Hughes v. United StatesCourt of Appeals for the Ninth Circuit · 1992
- Keene v. Comm'rUnited States Tax Court · 2003
- Talley Industries Inc. Consolidated Subsidiaries v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1997
- Yuen v. United StatesDistrict Court, D. Nevada · 2003
3Cited by3 opinions
- Calafati v. Comm'rUnited States Tax Court · 2006
- Calafati v. Comm'rUnited States Tax Court · 2006
- Dominic Calafati v. CommissionerUnited States Tax Court · 2006