Garrett v. Comm'r
United States Tax Court
P requested an Appeals hearing after receiving a notice of Federal tax lien for her taxable years 2004 through 2008. The IRS Appeals Office determined to proceed with collection of P's unpaid Federal income tax and additions to tax for those years, and P petitioned for review of that determination. Both P and R moved for summary judgment.
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P requested an Appeals hearing after receiving a notice of Federal tax lien for her taxable years 2004 through 2008. The IRS Appeals Office determined to proceed with collection of P's unpaid Federal income tax and additions to tax for those years, and P petitioned for review of that determination. Both P and R moved for summary judgment. P concedes liability for 2004 but denies receiving a notice of deficiency for 2005 through 2008. She argues that the copy of the notice of deficiency for those years and the certified mail list R submitted are not adequate evidence of mailing of the notice…
1Opinion of the Court
SHARON L. GARRETT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Garrett v. Comm'r
Docket No. 28049-14L.
United States Tax Court
T.C. Memo 2015-228; 2015 Tax Ct. Memo LEXIS 237; 110 T.C.M. (CCH) 498;
November 24, 2015, Filed
An order will be issued denying petitioner's motion for summary judgment, and granting in part, and denying in part, respondent's motion for summary judgment.
P requested an Appeals hearing after receiving a notice of Federal tax lien for her taxable years 2004 through 2008. The IRS Appeals Office determined to proceed with collection of P's unpaid Federal income…
2Cases cited26 opinions
- Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
- Hagner v. United StatesSupreme Court of the United States · 1932
- Sego v. CommissionerUnited States Tax Court · 2000
- Pennsylvania Coal Association, an Unincorporated Association v. Bruce Babbitt, Secretary of the Interior of the United States Department of Interior Robert Uram, Director, Office of Surface Mining Reclamation and Enforcement, United States Department of Interior, Pennsylvania Department of Environmental Resources (Der), Intervenor in D.C. Pennsylvania Coal Association, an Unincorporated Association v. Bruce Babbitt, Secretary of the Interior of the United States Department of Interior Robert Uram, Director, Office of Surface Mining Reclamation and Enforcement, United States Department of Interior Pennsylvania Department of Environmental Resources (Der), Intervenor in D.C. Commonwealth of Pennsylvania, Department of Environmental ResourcesCourt of Appeals for the Third Circuit · 1995
- United States v. Edward M. ZollaCourt of Appeals for the Ninth Circuit · 1984
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3Cited by1 opinion
- Garrett v. Comm'rUnited States Tax Court · 2016