Marcello v. Internal Revenue Service
This text of 414 F. App'x 560 (Marcello v. Internal Revenue Service) 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.
Opinion
Affirmed by unpublished PER CURIAM opinion.
Unpublished opinions are not binding precedent in this circuit.
Douglas Marcello appeals the district court’s orders dismissing his complaint against the Internal Revenue Service for failure to exhaust administrative remedies, upholding the Commissioner’s assessment of a trust fund recovery penalty against him, and reducing the assessment to judgment. We have reviewed the record and find no reversible error. Accordingly, we affirm for the reasons stated by the district court. Marcello v. Internal Rev. Serv., No. 1:08-cv-02796-RDB (D. Md. Apr. 21, May 3 & Nov. 12, 2010). 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.
AFFIRMED.
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414 F. App'x 560, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marcello-v-internal-revenue-service-ca4-2011.