Cox v. Comm'r
United States Tax Court
Ps' 1999 and 2000 taxable years became the subject of IRS collection activity through issuance of notices of intent to levy. Appeals Officer S thereafter conducted a simultaneous equivalent hearing with respect to 1999 and collection hearing pursuant to sec. 6330, I.R.C., with respect to 2000. A principal focus during that proceeding was the availability of collection alternatives.
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Ps' 1999 and 2000 taxable years became the subject of IRS collection activity through issuance of notices of intent to levy. Appeals Officer S thereafter conducted a simultaneous equivalent hearing with respect to 1999 and collection hearing pursuant to sec. 6330, I.R.C., with respect to 2000. A principal focus during that proceeding was the availability of collection alternatives. The Appeals Office sustained the proposed collection activity in November of 2003. Meanwhile, Ps' 2001 and 2002 taxable years had likewise become the subject of a notice of intent to levy. Ps' request for a hearing…
1Opinion of the Court
OPINION
Wherry, Judge:
These consolidated cases arise from petitions for judicial review filed in response to Notices of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330.1 The issue for decision is whether respondent may proceed with collection of income tax liabilities for years 2000, 2001, and 2002.
Background
These cases were submitted fully stipulated pursuant to Rule 122. The stipulations of the parties, with accompanying exhibits, are incorporated herein by this reference.
Petitioners are husband and wife. Petitioner Louis A. Cox (Mr. Cox) is a consulting engineer…
2Cases cited22 opinions
- Sego v. CommissionerUnited States Tax Court · 2000
- Woodral v. CommissionerUnited States Tax Court · 1999
- Davis v. CommissionerUnited States Tax Court · 2000
- Lunsford v. Comm'rUnited States Tax Court · 2001
- Katz v. CommissionerUnited States Tax Court · 2000
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3Cited by40 opinions
- Cox v. CommissionerCourt of Appeals for the Tenth Circuit · 2008
- Cavazos v. Comm'rUnited States Tax Court · 2008
- Calafati v. Comm'rUnited States Tax Court · 2006
- Catlow v. Comm'rUnited States Tax Court · 2007
- Moosally v. CommissionerUnited States Tax Court · 2014
35 more not listed; retrieve them via the Exa API.