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IAMES v. C.I.R.

No. 16-1154.

850 F.3d 160 (2017)

Christopher A. IAMES, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided: March 7, 2017.

Attorney(s) appearing for the Case

ARGUED: Alvah Lavar Taylor , Law Offices of A. Lavar Taylor, LLP, Santa Ana, California, for Appellant. Jennifer Marie Rubin , United States Department OF Justice, Washington, D.C., for Appellee. ON BRIEF: Jonathan T. Amitrano , LAW OFFICES OF A. LAVAR TAYLOR, LLP, Santa Ana, California; William Wise , WISE & STRACKS, Chicago, Illinois, for Appellant. Caroline D. Ciraolo , Principal Deputy Assistant Attorney General, Diana L. Erbsen , Deputy Assistant Attorney General, Gilbert S. Rothenberg , Michael J. Haungs , Tax Division, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee.

Affirmed by published opinion. Judge Wilkinson wrote the opinion, in which Judge Motz and Judge Diaz joined.

This tax administration case presents the question of whether the appellant, Christopher Iames, may contest his tax liability in a collection due process (CDP) hearing under Section 6330 of the Internal Revenue Code. Iames unsuccessfully challenged his liability in a preassessment...

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