Reed v. Commissioner
United States Tax Court
P failed to file Federal income tax returns timely for years 1987 through 2001. P subsequently submitted delinquent returns but failed to fully satisfy the outstanding tax liabilities. P submitted two separate offers-in-compromise (OICs) to settle the outstanding tax liabilities. R rejected the first OIC. R returned the second OIC. R issued a final notice of intent to levy.
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P failed to file Federal income tax returns timely for years 1987 through 2001. P subsequently submitted delinquent returns but failed to fully satisfy the outstanding tax liabilities. P submitted two separate offers-in-compromise (OICs) to settle the outstanding tax liabilities. R rejected the first OIC. R returned the second OIC. R issued a final notice of intent to levy. P requested a collection due process hearing (collection hearing). P raised issues during the collection hearing regarding R's handling of the two OICs and requested that the returned OIC be reopened. R concluded that he…
1Opinion of the Court
OPINION
Kroupa, Judge:
This collection review matter is before the Court because petitioner challenges a determination notice. See sec. 6330(d)(1). Respondent issued the determination notice sustaining a final notice of intent to levy (proposed levy action). The primary issue we are asked to decide is whether respondent abused his discretion in sustaining the proposed levy action. We hold he did not.
Determining whether respondent abused his discretion requires us to first consider three questions. Two of these questions involve well-trodden areas of law. The remaining question involves an issue…
2Cases cited15 opinions
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