Clark v. Comm'r
United States Tax Court
R issued a notice of levy on Ps' State tax refund to collect unpaid assessed additions to tax. After Ps requested a hearing under sec. 6330, I.R.C., on the appropriateness of the levy, R determined that the levy was appropriate. Held: The Court has jurisdiction under sec. 6330(d), I.R.C., to review R's determination regarding the levy upon Ps' State tax refund.
1Opinion of the Court
HERBERT AND ROSALIE CLARK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Clark v. Comm'r
No. 3082-05L
United States Tax Court
125 T.C. 108; 2005 U.S. Tax Ct. LEXIS 27; 125 T.C. No. 7;
September 26, 2005, Filed
R issued a notice of levy on Ps' State tax refund to collect
unpaid assessed additions to tax. After Ps requested a hearing
under sec. 6330, I.R.C., on the appropriateness of the levy, R
determined that the levy was appropriate.
Held: The Court has jurisdiction under sec. 6330(d),
I.R.C., to review R's determination regarding the levy upon Ps'
State tax refund.
Jeffrey E. Rattner and…
2Cases cited6 opinions
- American Fire & Casualty Co. v. FinnSupreme Court of the United States · 1951
- Naftel v. CommissionerUnited States Tax Court · 1985
- Raymond v. Comm'rUnited States Tax Court · 2002
- Neely v. CommissionerUnited States Tax Court · 2000
- Dorn v. Comm'rUnited States Tax Court · 2002
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