Moosally v. Commissioner
United States Tax Court
R rejected P's OIC for P's trust fund recovery penalties for the periods ending March 31 and September 30, 2000, and P's income tax liability for her 2008 tax year. P appealed R's rejection, and R assigned Appeals Officer S to review P's OIC. R also filed an NFTL for P's tax liabilities in issue and issued a Letter 3172. P requested a CDP hearing pursuant to I.R.C. sec. 6320, and R assigned Appeals Officer K to conduct P's CDP hearing.
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R rejected P's OIC for P's trust fund recovery penalties for the periods ending March 31 and September 30, 2000, and P's income tax liability for her 2008 tax year. P appealed R's rejection, and R assigned Appeals Officer S to review P's OIC. R also filed an NFTL for P's tax liabilities in issue and issued a Letter 3172. P requested a CDP hearing pursuant to I.R.C. sec. 6320, and R assigned Appeals Officer K to conduct P's CDP hearing. After Appeals Officer S had initiated review of P's OIC, R transferred P's CDP case from Appeals Officer K to Appeals Officer S. Appeals Officer S sustained…
1Opinion of the Court
Wells, Judge:
Petitioner seeks review, pursuant to section 6320, of respondent’s determination to proceed with collection of petitioner’s unpaid trust fund recovery penalty liabilities for periods ending March 31 and September 30, 2000, and also petitioner’s Federal income tax liability for her 2008 tax year. The issues we have been asked to decide are: (1) whether the Internal Revenue Service (IRS) Appeals Office settlement officer to whom petitioner’s case and hearing were assigned was an impartial officer pursuant to section 6320(b)(3), and (2) if she was an impartial officer, whether…
2Cases cited19 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Naftel v. CommissionerUnited States Tax Court · 1985
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987
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3Cited by4 opinions
- Guralnik v. Comm'rUnited States Tax Court · 2016
- Alternative Carbon Resources, LLC v. United StatesUnited States Court of Federal Claims · 2018
- Lincoln C. Pearson & Victoria K. Pearson v. CommissionerUnited States Tax Court · 2017
- Patricia A. Moosally v. CommissionerUnited States Tax Court · 2014