Shanley v. Comm'r
United States Tax Court
P failed to pay his self-reported Federal income tax liability for the year 2006, and R issued a notice of intent to levy. P requested a hearing under I.R.C. sec. 6330, indicating a desire for an installment agreement. R's Office of Appeals requested that P provide financial information within 14 days. P asked for an extension of time to submit the requested financial information. R's appeals officer denied that request.
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P failed to pay his self-reported Federal income tax liability for the year 2006, and R issued a notice of intent to levy. P requested a hearing under I.R.C. sec. 6330, indicating a desire for an installment agreement. R's Office of Appeals requested that P provide financial information within 14 days. P asked for an extension of time to submit the requested financial information. R's appeals officer denied that request. P did not provide any of the information by the time of the hearing. R's appeals officer issued to P a notice of determination in which he determined that a levy was…
1Opinion of the Court
TERENCE E. SHANLEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Shanley v. Comm'r
No. 3046-08L
United States Tax Court
T.C. Memo 2009-17; 2009 Tax Ct. Memo LEXIS 17; 97 T.C.M. (CCH) 1057;
January 28, 2009., Filed
P failed to pay his self-reported Federal income tax liability for the year 2006, and R issued a notice of intent to levy. P requested a hearing under I.R.C. sec. 6330, indicating a desire for an installment agreement. R's Office of Appeals requested that P provide financial information within 14 days. P asked for an extension of time to submit the requested financial…
2Cases cited18 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
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- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
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- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
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