United States Sixth Circuit

In a challenge to the Treasury Department's so-called "check-the-box" regulations, which were promulgated in 1996 to simplify the classification of business entities for tax purposes, summary judgment for the government is affirmed where the district court: 1) correctly held that the regulations were "a reasonable response to the changes in the state law industry of business formation"; 2) upheld them under Chevron analysis; and 3) held that plaintiff was individually liable for the employment taxes at issue.

Appellate Information

• Decided 04/13/2007
• Published 04/13/2007

Judges

• Before KENNEDY and DAUGHTREY, Circuit Judges;  ADAMS, District Judge.

Court

• United States Sixth Circuit

Counsel

• For Appellees:
  
• ARGUED:  Irwin G. Waterman, Seiller Waterman LLC, Louisville, Kentucky, for Appellant.  Bridget M. Rowan, United States Department of Justice, Washington, D.C., for Appellees.   ON BRIEF:  Irwin G. Waterman, Michael T. Hymson, Seiller Waterman LLC, Louisville, Kentucky, for Appellant.  Bridget M. Rowan, David I. Pincus, United States Department of Justice, Washington, D.C., for Appellees.