Legal Opinion

Boyd v. Comm'r

United States Tax Court

Decided September 28, 2001No. 6677-00LPublished

HELD: Petitioner's request for a sec. 6330 hearing suspended the applicable 10-year limitations period for collecting petitioner's Federal income taxes for taxable years 1989 and 1990, and respondent is not time barred from collecting those taxes. HELD, FURTHER, petitioner has failed to show that he paid the subject tax liabilities for taxable years 1991, 1992, 1993, 1996, and 1997. HELD, FURTHER, petitioner's request for a new trial is denied.

1Opinion of the Court

GARY G. BOYD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Boyd v. Comm'r

No. 6677-00L

United States Tax Court

117 T.C. 127; 2001 U.S. Tax Ct. LEXIS 43; 117 T.C. No. 12;

September 28, 2001, Filed

Decision will be entered for respondent.

HELD: Petitioner's request for a sec. 6330 hearing

suspended the applicable 10-year limitations period for

collecting petitioner's Federal income taxes for taxable years

1989 and 1990, and respondent is not time barred from collecting

those taxes.

HELD, FURTHER, petitioner has failed to show that he paid

the subject tax liabilities for taxable years 1991,…

2Cases cited12 opinions

  1. Tokarski v. CommissionerUnited States Tax Court · 1986
  2. Cupp v. CommissionerUnited States Tax Court · 1975
  3. Davis v. CommissionerUnited States Tax Court · 2000
  4. Riland v. CommissionerUnited States Tax Court · 1982
  5. Landry v. CommissionerUnited States Tax Court · 2001

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