Greene-Thapedi v. Comm'r
United States Tax Court
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
- Commissioner v. SunnenSupreme Court of the United States · 1948
- North Carolina v. RiceSupreme Court of the United States · 1971
- Tcherepnin v. KnightSupreme Court of the United States · 1967
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- United States v. DalmSupreme Court of the United States · 1990
47 more not listed; retrieve them via the Exa API.