Aguirre v. Comm'r
United States Tax Court
Petitioners (Ps) filed returns for 1992-94. Respondent (R) examined those returns, and Ps signed a Form 4549, Income Tax Examination Changes, in which they waived the right to contest their tax liability in the Tax Court and consented to the immediate assessment and collection of tax for 1992-94. R issued to Ps a notice of intent to levy with respect to Ps' taxes due for tax years 1992-94. Ps requested a hearing pursuant to sec. 6330(b), I.R.C., solely to dispute the amount…
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Petitioners (Ps) filed returns for 1992-94. Respondent (R) examined those returns, and Ps signed a Form 4549, Income Tax Examination Changes, in which they waived the right to contest their tax liability in the Tax Court and consented to the immediate assessment and collection of tax for 1992-94. R issued to Ps a notice of intent to levy with respect to Ps' taxes due for tax years 1992-94. Ps requested a hearing pursuant to sec. 6330(b), I.R.C., solely to dispute the amount of their tax liabilities for 1992-94. R sent a notice of determination to Ps stating that collection of their tax…
1Opinion of the Court
OPINION
Colvin, Judge:
This matter is before the Court on respondent’s motion for summary judgment. For reasons stated below, we will grant respondent’s motion.
All section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Background
Petitioners are married and lived in Hacienda Heights, California, when they filed their petition.
Petitioners filed joint returns for 1992, 1993, and 1994. Respondent examined petitioners’ 1992, 1993, and 1994 returns in 1995. On July 13, 1995, petitioners signed a Form 4549, Income…
2Cases cited9 opinions
- Sego v. CommissionerUnited States Tax Court · 2000
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
- Jacklin v. CommissionerUnited States Tax Court · 1982
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3Cited by38 opinions
- Perez v. United StatesCourt of Appeals for the Fifth Circuit · 2002
- Kendricks v. Comm'rUnited States Tax Court · 2005
- Urbano v. Comm'rUnited States Tax Court · 2004
- Estate of Robert C. Duncan v. CIRCourt of Appeals for the Fifth Circuit · 2018
- Zapara v. Comm'rUnited States Tax Court · 2005
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