Minihan v. Comm'r
United States Tax Court
P petitioned for review of R's denial of innocent spouse relief under I.R.C. sec. 6015(f), and R created a separate account for each spouse in order to pursue collection from I (P's former husband) while collection against P was suspended pursuant to I.R.C. sec. 6015(e)(1)(B). While P's petition was pending, R collected the entire tax liability at issue by levying on a bank account owned jointly by P and I. As a result, P now seeks a refund pursuant to I.R.C. sec.…
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P petitioned for review of R's denial of innocent spouse relief under I.R.C. sec. 6015(f), and R created a separate account for each spouse in order to pursue collection from I (P's former husband) while collection against P was suspended pursuant to I.R.C. sec. 6015(e)(1)(B). While P's petition was pending, R collected the entire tax liability at issue by levying on a bank account owned jointly by P and I. As a result, P now seeks a refund pursuant to I.R.C. sec. 6015(g)(1), in the amount of 50% of the funds levied from the joint account. R contends that P is not entitled to a refund of…
1Opinion of the Court
ANN MARIE MINIHAN, Petitioner, AND JOHN J. MINIHAN, JR., Intervenor v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Minihan v. Comm'r
Docket No. 26595-09.
United States Tax Court
138 T.C. 1; 2012 U.S. Tax Ct. LEXIS 1; 138 T.C. No. 1;
January 11, 2012, Filed
An appropriate order will be issued.
P petitioned for review of R's denial of innocent spouse relief under I.R.C. sec. 6015(f), and R created a separate account for each spouse in order to pursue collection from I (P's former husband) while collection against P was suspended pursuant to I.R.C. sec. 6015(e)(1)(B). While P's petition was pending, R…
2Cases cited31 opinions
- Zenith Radio Corp. v. Hazeltine Research, Inc.Supreme Court of the United States · 1971
- United States v. DalmSupreme Court of the United States · 1990
- United States v. RodgersSupreme Court of the United States · 1983
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
- National Life Insurance v. United StatesSupreme Court of the United States · 1928
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