Dutton v. Comm'r
United States Tax Court
P submitted a request for relief from joint and several liability. P subsequently submitted an offer in compromise, which R accepted. Before the offer was accepted, R sent P a letter explaining that it was proposed that P be granted relief under sec. 6015(c), I.R.C., and that P would be entitled to a refund.
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P submitted a request for relief from joint and several liability. P subsequently submitted an offer in compromise, which R accepted. Before the offer was accepted, R sent P a letter explaining that it was proposed that P be granted relief under sec. 6015(c), I.R.C., and that P would be entitled to a refund. After accepting the offer, R sent P a notice of determination denying relief from joint and several liability under former sec. 6013(e), I.R.C., and sec. 6015(b), (c), and (f), I.R.C. P petitioned the Court under sec. 6015(e)(1), I.R.C. P argues that the statement that P would be entitled…
1Opinion of the Court
OPINION
Goeke, Judge:
This matter is before the Court on the issue of whether petitioner is barred from seeking relief from joint and several liability under former section 6013(e)1 and section 6015 for the years 1986 and 1987 because he entered into an offer in compromise with respondent for those years. We hold that the offer in compromise is valid and petitioner is barred from seeking relief from joint and several liability.
Background
The parties submitted the issue fully stipulated. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioner’s…
2Cases cited13 opinions
- Woods v. CommissionerUnited States Tax Court · 1989
- Krause v. CommissionerUnited States Tax Court · 1992
- Hildebrand v. CommissionerCourt of Appeals for the Tenth Circuit · 1994
- Dorchester Indus. v. Comm'rUnited States Tax Court · 1997
- United States v. LaneCourt of Appeals for the Fifth Circuit · 1962
8 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
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- Ray v. CIRCourt of Appeals for the Fifth Circuit · 2021
- Larosa's International Fuel Co. v. United StatesUnited States Court of Federal Claims · 2006
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