United States Second Circuit

Defendant's determination that plaintiff is personally liable for the employment tax liabilities of his wholly owned limited-liability company, which he had chosen not to have treated as a corporation is affirmed over claim that the Treasury Regulations, and hence defendant's determination, were contrary to: 1) state law treating an LLC and its members as separate entities; and 2) provisions of the Internal Revenue Code.

Appellate Information

• Decided 05/23/2007
• Published 05/23/2007

Judges

• KEARSE, Circuit Judge., Before KEARSE and STRAUB, Circuit Judges, and KEENAN, District Judge .

Court

• United States Second Circuit

Counsel

• For Appellant:
  
• Sean P. McNamee, Wallingford, CT, Plaintiff-Appellant pro se.


• For Appellees:
  
• Bridget M. Rowan, Attorney, Tax Division, Department of Justice, Washington, D.C. (Eileen J. O'Connor, Assistant Attorney General, David I. Pincus, Attorney, Tax Division, Washington, D.C., Kevin J. O'Connor, United States Attorney for the District of Connecticut, on the brief), for Defendant-Appellee.