Legal Opinion

Leahy v. Comm'r

United States Tax Court

Decided September 17, 2007No. 17199-06LPublished

Ps filed a petition pursuant to sec. 6330(d), I.R.C., challenging R's determination concerning collection of Ps' unpaid income tax for the years 19962000. Ps requested that their case be conducted under the small tax case procedures authorized by sec. 7463(f)(2), I.R.C., in the case of "an appeal under section 6330(d)(1)(A) to the Tax Court of a determination in which the unpaid tax does not exceed $ 50,000." On the date respondent issued the notice of determination, the…

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Ps filed a petition pursuant to sec. 6330(d), I.R.C., challenging R's determination concerning collection of Ps' unpaid income tax for the years 19962000. Ps requested that their case be conducted under the small tax case procedures authorized by sec. 7463(f)(2), I.R.C., in the case of "an appeal under section 6330(d)(1)(A) to the Tax Court of a determination in which the unpaid tax does not exceed $ 50,000." On the date respondent issued the notice of determination, the total amount of unpaid tax exceeded $ 50,000. Nevertheless, Ps contend that because they dispute less than $ 50,000 of the…

1Opinion of the Court

MICHAEL PATRICK AND DEBYE LEE LEAHY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Leahy v. Comm'r

No. 17199-06L

United States Tax Court

129 T.C. 71; 2007 U.S. Tax Ct. LEXIS 27; 129 T.C. No. 8;

September 17, 2007, Filed

Ps filed a petition pursuant to sec. 6330(d), I.R.C., challenging R's determination concerning collection of Ps' unpaid income tax for the years 19962000. Ps requested that their case be conducted under the small tax case procedures authorized by sec. 7463(f)(2), I.R.C., in the case of "an appeal under section 6330(d)(1)(A) to the Tax Court of a determination in which…

2Cases cited11 opinions

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. American Tobacco Co. v. PattersonSupreme Court of the United States · 1982
  3. United States v. MerriamSupreme Court of the United States · 1923
  4. United States v. Campos-SerranoSupreme Court of the United States · 1971
  5. Stewart v. Comm'rUnited States Tax Court · 2006

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