Legal Opinion

Kelvin R. Crews v. Commissioner

United States Tax Court

Decided June 27, 2019No. 18940-16LUnpublished

1Opinion of the Court

T.C. Memo. 2019-80

UNITED STATES TAX COURT KELVIN R. CREWS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18940-16L. Filed June 27, 2019. R assessed trust-fund-recovery penalties against P regarding the employment taxes of two employers: (1) ES for the four quarters from 2Q 2008 to 1Q 2009 and (2) KC for the seven quarters from 2Q 2008 to 4Q 2009. P made administrative claims with R challenging the trust-fund-recovery penalties. The administrative claims were denied by a tax examiner. P sent a letter to R to administratively appeal the trust-fund- recovery penalties.…

2Cases cited16 opinions

  1. United States v. Richard Junior FrazierCourt of Appeals for the Eleventh Circuit · 2004
  2. Goza v. CommissionerUnited States Tax Court · 2000
  3. Slodov v. United StatesSupreme Court of the United States · 1978
  4. Murphy v. Commissioner of IRSCourt of Appeals for the First Circuit · 2006
  5. Murphy v. Comm'rUnited States Tax Court · 2005

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