Lindsay Manor Nursing Home, Inc. v. Comm'r
United States Tax Court
At its CDP hearing P, a corporate taxpayer, challenged the appropriateness of a proposed levy on the grounds that the levy would create economic hardship because of the financial condition of P. R's settlement officer (SO) did not consider P's economic hardship argument because P is a corporate taxpayer and sec. 301.6343-1(b)(4)(i), Proced. & Admin. Regs., limits economic hardship relief to individual taxpayers.
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At its CDP hearing P, a corporate taxpayer, challenged the appropriateness of a proposed levy on the grounds that the levy would create economic hardship because of the financial condition of P. R's settlement officer (SO) did not consider P's economic hardship argument because P is a corporate taxpayer and sec. 301.6343-1(b)(4)(i), Proced. & Admin. Regs., limits economic hardship relief to individual taxpayers. P asserts in a motion for summary judgment that sec. 301.6343-1(b)(4)(i), Proced. & Admin. Regs., is invalid because it conflicts with I.R.C. sec. 6343(a)(1)(D) and that because the…
1Opinion of the Court
LINDSAY MANOR NURSING HOME, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Lindsay Manor Nursing Home, Inc. v. Comm'r
Docket No. 24596-14L
United States Tax Court
2017 U.S. Tax Ct. LEXIS 10; 148 T.C. No. 9;
March 23, 2017, Filed
An appropriate order will be issued.
At its CDP hearing P, a corporate taxpayer, challenged the appropriateness of a proposed levy on the grounds that the levy would create economic hardship because of the financial condition of P. R's settlement officer (SO) did not consider P's economic hardship argument because P is a corporate taxpayer and sec.…
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