The following excerpt is from DeMartino v. C.I.R., 862 F.2d 400 (2nd Cir. 1988):
1 This decision was summarily affirmed as to DeMartino's partner in McDonnell v. Commissioner, 862 F.2d 308 (3d Cir.1988).
2 Section 6621 provides that:
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexi.com.