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AHMED v. C.I.R.

No. 22-1091.

64 F.4th 477 (2023)

Faisal AHMED, Appellant v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

(Opinion Filed: April 7, 2023).

Attorney(s) appearing for the Case

Frank Agostino, Phillip Colasanto [Argued], Agostino & Associates, 14 Washington Place, Hackensack, NJ 07601, Counsel for Appellant.

David Hubbert, Michael J. Haungs, Carl D. Wasserman [Argued], Tax Division, Department of Justice, 950 Pennsylvania Avenue, N.W., Post Office Box 502, Washington, D.C. 20044, Counsel for the Appellee.

Before: AMBRO, KRAUSE, and BIBAS, Circuit Judges.

OPINION OF THE COURT

In 2017, the Internal Revenue Service (IRS) moved to penalize Faisal Ahmed for his company's delinquent trust fund taxes. It first attempted to notify Ahmed of its proposed penalties. Whether he received that notification is unclear. There is no doubt, however, that the IRS went ahead and assessed...

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