Thompson v. Commissioner
United States Tax Court
P filed a petition for review pursuant to I.R.C. sec. 6330 in response to R's determination to proceed with collection. P sought a collection alternative of a partial payment installment agreement with a monthly payment of $3,000. The Internal Revenue Manual provides guidance for determining how much a taxpayer should be able to pay in a partial payment installment agreement and how much should be set aside for the taxpayer's necessary living expenses.
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P filed a petition for review pursuant to I.R.C. sec. 6330 in response to R's determination to proceed with collection. P sought a collection alternative of a partial payment installment agreement with a monthly payment of $3,000. The Internal Revenue Manual provides guidance for determining how much a taxpayer should be able to pay in a partial payment installment agreement and how much should be set aside for the taxpayer's necessary living expenses. The Internal Revenue Manual provides that in a partial payment installment agreement a taxpayer is allowed only necessary expenses;…
1Opinion of the Court
Ruwe, Judge:
This proceeding was commenced in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. 1 The issues for decision are whether it was an abuse of discretion for the settlement officer to reject petitioner’s contention that: (1) petitioner’s monthly tithing to his Church and (2) his monthly payments for his children’s college expenses should be excluded from the monthly amount available to satisfy his unpaid tax liabilities. Petitioner contends that respondent’s failure to allow for his tithing obligations violates the Free Exercise…
2Cases cited31 opinions
- Harris v. McRaeSupreme Court of the United States · 1980
- Hernandez v. CommissionerSupreme Court of the United States · 1989
- Goza v. CommissionerUnited States Tax Court · 2000
- United States v. CaceresSupreme Court of the United States · 1979
- United States v. LeeSupreme Court of the United States · 1982
26 more not listed; retrieve them via the Exa API.
3Cited by85 opinions
- Moriarty v. Comm'rUnited States Tax Court · 2017
- Rebuck v. Comm'rUnited States Tax Court · 2016
- Triola v. Comm'rUnited States Tax Court · 2014
- Cropper v. Comm'rUnited States Tax Court · 2014
- Hosie v. Comm'rUnited States Tax Court · 2014
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