Gould v. Commissioner

Fourth Circuit

Gould v. Commissioner

119 F. App'x 571

CourtCourt of Appeals for the Fourth Circuit

DecidedFebruary 1, 2005

DocketNo. 04-2035

StatusPublished

This text of 119 F. App'x 571 (Gould v. Commissioner) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Gould v. Commissioner, 119 F. App'x 571 (4th Cir. 2005).

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Opinion

PER CURIAM:

Theodore B. Gould and Helen C. Gould appeal from the tax court’s order determining that the IRS could not proceed with its proposed collection action with respect to the Goulds’ 1997 tax year liability. The Goulds argue that the tax court should have addressed their challenge to the liability determination. However, because the Goulds were not aggrieved by the tax court’s order, they lack standing to appeal. See Deposit Guar. Nat’l Bank v. Roper, 445 U.S. 326, 333-35, 100 S.Ct. 1166, 63 L.Ed.2d 427 (1980); HCA Health Servs. of Va. v. Metro. Life Ins. Co., 957 F.2d 120, 123 (4th Cir.1992). Accordingly, we dismiss the appeal. We dispense with oral argument because the facts and legal contentions are adequately presented in the materials before the court and argument would not aid the decisional process.

DISMISSED

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PER CURIAM:

Theodore B. Gould and Helen C. Gould appeal from the tax court’s order determining that the IRS could not proceed with its proposed collection action with respect to the Goulds’ 1997 tax year liability. The Goulds argue that the tax court should have addressed their challenge to the liability determination. However, because the Goulds were not aggrieved by the tax court’s order, they lack standing to appeal. See Deposit Guar. Nat’l Bank v. Roper, 445 U.S. 326, 333-35, 100 S.Ct. 1166, 63 L.Ed.2d 427 (1980); HCA Health Servs. of Va. v. Metro. Life Ins. Co., 957 F.2d 120, 123 (4th Cir.1992). Accordingly, we dismiss the appeal. We dispense with oral argument because the facts and legal contentions are adequately presented in the materials before the court and argument would not aid the decisional process.

DISMISSED

Hca Health Services of Virginia, T/a Henrico Doctors' Hospital Richmond Community Hospital, a Virginia Non-Stock Corporation Richmond Eye and Ear Hospital, a Virginia Non-Stock Corporation v. Metropolitan Life Insurance Company, a New York Corporation Metlife Healthcare Management Corporation, a Delaware Corporation, Hca Health Services of Virginia, T/a Henrico Doctors' Hospital Richmond Community Hospital, a Virginia Non-Stock Corporation Richmond Eye and Ear Hospital, a Virginia Non-Stock Corporation v. Metropolitan Life Insurance Company, a New York Corporation Metlife Healthcare Management Corporation, a Delaware Corporation

957 F.2d 120 (Fourth Circuit, 1992)

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Bluebook (online)

119 F. App'x 571, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gould-v-commissioner-ca4-2005.

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