Legal Opinion

Greene-Thapedi v. Comm'r

United States Tax Court

Decided January 12, 2006No. 7940-01LPublished

In her original petition, P challenged R's notice of determination sustaining a proposed levy to collect P's 1992 income tax. She contended, among other things, that R had failed to make a timely assessment of her 1992 tax liabilities and had included excessive interest accruals in her 1992 balance due; she sought a refund of certain amounts previously paid with respect to her 1992 account.

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In her original petition, P challenged R's notice of determination sustaining a proposed levy to collect P's 1992 income tax. She contended, among other things, that R had failed to make a timely assessment of her 1992 tax liabilities and had included excessive interest accruals in her 1992 balance due; she sought a refund of certain amounts previously paid with respect to her 1992 account. After the petition was filed, P's 1992 balance due was eliminated by R's offset of P's 1999 overpayment, pursuant to sec. 6402(a), I.R.C. P amended her petition in the Tax Court, seeking an increased…

1Opinion of the Court

LLWELLYN GREENE-THAPEDI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Greene-Thapedi v. Comm'r

No. 7940-01L

United States Tax Court

126 T.C. 1; 2006 U.S. Tax Ct. LEXIS 1; 126 T.C. No. 1;

January 12, 2006, Filed

In her original petition, P challenged R's notice of

determination sustaining a proposed levy to collect P's 1992

income tax. She contended, among other things, that R had failed

to make a timely assessment of her 1992 tax liabilities and had

included excessive interest accruals in her 1992 balance due;

she sought a refund of certain amounts previously paid with

respect to her 1992…

Also in this document: Concurrence · Foley; Concurrence · Colvin; Dissent.

2Cases cited52 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. North Carolina v. RiceSupreme Court of the United States · 1971
  3. Tcherepnin v. KnightSupreme Court of the United States · 1967
  4. Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
  5. United States v. DalmSupreme Court of the United States · 1990

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