Trout v. Comm'r
United States Tax Court
In 1997, P entered into an offer-in-compromise (OIC) covering tax years 1989, 1990, 1991, and 1993. The OIC included a term requiring P to timely file and pay his taxes for five years. P filed his 1996 tax return late, then failed to file 1998 and 1999 returns. P filed his 1998 taxes, showing a refund due, in November 2003, but failed to sign his 1999 return, which showed a liability of $ 164. In March 2004, R sent P a notice of intent to levy and P requested a CDP hearing.
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In 1997, P entered into an offer-in-compromise (OIC) covering tax years 1989, 1990, 1991, and 1993. The OIC included a term requiring P to timely file and pay his taxes for five years. P filed his 1996 tax return late, then failed to file 1998 and 1999 returns. P filed his 1998 taxes, showing a refund due, in November 2003, but failed to sign his 1999 return, which showed a liability of $ 164. In March 2004, R sent P a notice of intent to levy and P requested a CDP hearing. P paid his liability for 1999 but still failed to file a signed return. R issued a notice of determination upholding the…
1Opinion of the Court
DAVID W. TROUT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Trout v. Comm'r
No. 5690-05L
United States Tax Court
131 T.C. 239; 2008 U.S. Tax Ct. LEXIS 34; 131 T.C. No. 16;
December 16, 2008, Filed
In 1997, P entered into an offer-in-compromise (OIC) covering tax years 1989, 1990, 1991, and 1993. The OIC included a term requiring P to timely file and pay his taxes for five years. P filed his 1996 tax return late, then failed to file 1998 and 1999 returns. P filed his 1998 taxes, showing a refund due, in November 2003, but failed to sign his 1999 return, which showed a liability of $…
Also in this document: Concurrence.
2Cases cited29 opinions
- Cooter & Gell v. Hartmarx Corp.Supreme Court of the United States · 1990
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Boyle v. United Technologies Corp.Supreme Court of the United States · 1988
- United States v. Kimbell Foods, Inc.Supreme Court of the United States · 1979
- Clearfield Trust Co. v. United StatesSupreme Court of the United States · 1943
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