Frank A. Littriello v. United States of America and United States Department of Treasury

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that because plaintiff’s companies were disregarded entities, “he is . . . liable individually for the employment taxes due and owing from those businesses”
• rejecting the plaintiffs argument “that the IRS must recognize the separate existence of his LLCs as a matter of state law”
• discussing a single-member LLC’s option to treat an LLC as a corporation or have it treated as a sole proprietorship for tax purposes in the absence of such an election
• describing pass-through taxation of sole proprietorships, where “a single individual owns all the assets, is liable for all debts, and operates in an individual capacity [and] is also taxed only once”
• upholding district court’s determination that § 301.7701-2 is valid under Chevon analysis
• “The federal government has historically disregarded state classifications of businesses for some federal tax purposes.”

Source: CourtListener parenthetical corpus (CC0).