Urbano v. Comm'r
United States Tax Court
Following R's audit of Ps' 1993 through 1996 Federal income tax returns, R's revenue agent (A) prepared a Form 4549-CG, Income Tax Examination Changes, that listed $ 7,556.09 as the total amount of Federal income taxes, penalties, and interest Ps owed for those years.
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Following R's audit of Ps' 1993 through 1996 Federal income tax returns, R's revenue agent (A) prepared a Form 4549-CG, Income Tax Examination Changes, that listed $ 7,556.09 as the total amount of Federal income taxes, penalties, and interest Ps owed for those years. Ps signed the form, consenting to R's immediate assessment and collection of the $ 7,556.09 and waiving their right to challenge in this Court the findings of A contained in that form, and delivered the signed form to A with a check for the stated amount. Subsequently, R determined that A had understated the interest due for…
1Opinion of the Court
OPINION
Laro, Judge:
This case is before the Court for decision without trial. See Rule 122.1 Petitioners petitioned the Court under section 6330(d)(1), as made applicable by section 6320(c), to review the determination of respondent’s Office of Appeals (Appeals) sustaining respondent’s filing of a notice of Federal tax lien (nftl). Respondent filed the NFTL to secure the payment of $31,455.49 shown in his records to be due from petitioners as of March 25, 2002, with respect to their 1993 Federal income tax. The $31,455.49 is all attributable to interest (disputed interest) that respondent…
2Cases cited18 opinions
- Insurance Corp. of Ireland v. Compagnie Des Bauxites De GuineeSupreme Court of the United States · 1982
- Sego v. CommissionerUnited States Tax Court · 2000
- Naftel v. CommissionerUnited States Tax Court · 1985
- Woodral v. CommissionerUnited States Tax Court · 1999
- Katz v. CommissionerUnited States Tax Court · 2000
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3Cited by51 opinions
- Greene-Thapedi v. Comm'rUnited States Tax Court · 2006
- Lewis v. Comm'rUnited States Tax Court · 2007
- Corson v. Comm'rUnited States Tax Court · 2004
- Manko v. Comm'rUnited States Tax Court · 2006
- Corbalis v. Comm'rUnited States Tax Court · 2014
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