Murphy v. Comm'r
United States Tax Court
P asks us to review a determination by R's settlement officer (SO) that R may proceed with collection by levy of P's unpaid tax liability for 1999. P claims that the SO abused her discretion by (1) rejecting P's offer in compromise, based alternatively on doubt as to collectibility and the promotion of effective tax administration, and (2) improperly and prematurely concluding P's hearing.
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P asks us to review a determination by R's settlement officer (SO) that R may proceed with collection by levy of P's unpaid tax liability for 1999. P claims that the SO abused her discretion by (1) rejecting P's offer in compromise, based alternatively on doubt as to collectibility and the promotion of effective tax administration, and (2) improperly and prematurely concluding P's hearing. R objects to P's testimony as to reasons he did not pay his 1992-2001 tax liabilities as they came due and the SO's testimony as to entries in her case activity notes and certain aspects of her handling of…
1Opinion of the Court
Halpern, Judge:
This case is before the Court to review a determination made by one of respondent’s Appeals officers that respondent may proceed to collect by levy unpaid taxes with respect to petitioner’s 1999 tax year. We review the determination pursuant to section 6330(d)(1).
Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. Dollar amounts have been rounded to the nearest dollar.
FINDINGS OF FACT
Some facts have been stipulated and are so found. The stipulation…
2Cases cited20 opinions
- Citizens to Preserve Overton Park, Inc. v. VolpeSupreme Court of the United States · 1971
- Califano v. SandersSupreme Court of the United States · 1977
- Florida Power & Light Co. v. LorionSupreme Court of the United States · 1985
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Goza v. CommissionerUnited States Tax Court · 2000
15 more not listed; retrieve them via the Exa API.
3Cited by296 opinions
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- David and Lynette Kindred v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2006
- Weber v. CommissionerUnited States Tax Court · 2012
- Johnson v. CommissionerUnited States Tax Court · 2011
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