Moore v. Commissioner
United States Tax Court
The Tax Court has held that it lacks jurisdiction to review a responsible person's administrative appeal under section 6320 because it lacks jurisdiction over the underlying taxes and penalties arising under section 6672. The Tax Court has held that it lacks jurisdiction to review a responsible person's administrative appeal under section 6320 because it lacks jurisdiction over the underlying taxes and penalties arising under section 6672. Janet Moore was an officer of a…
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The Tax Court has held that it lacks jurisdiction to review a responsible person's administrative appeal under section 6320 because it lacks jurisdiction over the underlying taxes and penalties arising under section 6672. The Tax Court has held that it lacks jurisdiction to review a responsible person's administrative appeal under section 6320 because it lacks jurisdiction over the underlying taxes and penalties arising under section 6672. Janet Moore was an officer of a now-bankrupt corporation that failed to pay FICA and employee income tax withholdings to the government. The IRS determined…
1Opinion of the Court
OPINION
Cohen, Chief Judge:
This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183. Unless otherwise indicated, section references are to sections of the Internal Revenue Code as amended, and Rule references to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Panuthos, Chief Special Trial Judge: This matter is before the Court on respondent’s motion to dismiss for lack of…
2Cases cited3 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Naftel v. CommissionerUnited States Tax Court · 1985
- Henry Randolph Consulting v. CommissionerUnited States Tax Court · 1999
3Cited by80 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Katz v. CommissionerUnited States Tax Court · 2000
- Offiler v. CommissionerUnited States Tax Court · 2000
- Lunsford v. Comm'rUnited States Tax Court · 2001
- Olsen v. United StatesCourt of Appeals for the First Circuit · 2005
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