Pelliccio v. United States

How courts have described this case

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

• holding that a taxpayer who was notified of his liability and offered an opportunity for an Appeals hearing, could not dispute the liability again in a collection review hearing
• holding that a taxpayer who was notified of his liability and offered an opportunity for an Appeals hearing, could not dispute the liability again in a collection review hearing
• holding that a taxpayer who was notified of his liability and - 7 - offered an opportunity for an Appeals hearing, could not dispute the liability again in a collection review hearing
• noting that the taxpayer in that case “did not propose any alternatives,” despite being advised by the Appeals Officer “numerous times that he would consider any proposed alternatives to collection”

Source: CourtListener parenthetical corpus (CC0).