United States Second Circuit

In case involving challenge to extent of tax liabilities for three years, summary judgment for respondent commissioner is affirmed as: 1) petitioner previously had an opportunity to dispute his liabilities for two of the years; and 2) respondent properly declined to accept his amended tax return for the remaining year.

Appellate Information

• Decided 03/02/2007
• Published 03/02/2007

Judges

• JOSÉ A. CABRANES, Circuit Judge., Before KEARSE, CABRANES, and KATZMANN, Circuit Judges.

Court

• United States Second Circuit

Counsel

• For Appellant:
  
• Ira B. Stechel (John T. Morin and Jennifer L. Marlborough, on the brief), Wormser, Kiely, Galef & Jacobs LLP, New York, NY, for petitioner.


• For Appellees:
  
• Randolph H. Hutter, Attorney (Eileen J. O'Connor, Assistant Attorney General, and Jonathan S. Cohen, Attorney, on the brief), Tax Division, Department of Justice, Washington, DC, for respondent.