OLSEN v. U.S.

No. 04-2156.

414 F.3d 144 (2005)

Richard E. OLSEN, Plaintiff, Appellant, v. UNITED STATES, Defendant, Appellee.

United States Court of Appeals, First Circuit.

Decided July 8, 2005.


Attorney(s) appearing for the Case

Timothy J. Burke for appellant.

Jonathan S. Cohen, Tax Division, Department of Justice, with whom Eileen J. O'Connor, Assistant Attorney General, John Schumann, Tax Division, Department of Justice, and Michael J. Sullivan, United States Attorney, were on brief for appellee.

Before BOUDIN, Chief Judge, CAMPBELL, Senior Circuit Judge, and GERTNER, District Judge.


CAMPBELL, Senior Circuit Judge.

Plaintiff-Appellant Richard E. Olsen ("Olsen") appeals from a judgment of the United States District Court for the District of Massachusetts affirming an administrative determination by the Internal Revenue Service ("IRS") Office of Appeals permitting the IRS to collect by levy unpaid employment taxes and penalties owed by Olsen. See Olsen v. United States, 326 F.Supp.2d 184 (D.Mass.2004...

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