Legal Opinion

Katz v. Commissioner

United States Tax Court

Decided October 13, 2000No. 16718-99LPublishedCited by 207 opinions

P received a notice of deficiency for his 1990 tax year. After P petitioned this Court to redetermine that deficiency determination, the Court entered a stipulated decision providing for a tax deficiency, additions to tax, and statutory interest. R subsequently filed a lien, and P, in turn, requested an Appeals hearing from R's Appeals Office pursuant to sec. 6320(b), I.R.C.

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P received a notice of deficiency for his 1990 tax year. After P petitioned this Court to redetermine that deficiency determination, the Court entered a stipulated decision providing for a tax deficiency, additions to tax, and statutory interest. R subsequently filed a lien, and P, in turn, requested an Appeals hearing from R's Appeals Office pursuant to sec. 6320(b), I.R.C. P refused to appear at the Appeals hearing on the grounds that the location of the Appeals hearing was inconvenient to P and his witnesses. After an Appeals officer discussed the collection matter with P via telephone,…

1Opinion of the Court

OPINION

VASQUEZ, Judge:

Petitioner filed a petition in response to respondent’s notice of determination concerning collection action(s) under section 6320 and/or 6330 (notice of determination).1 In his petition, petitioner alleges that the Internal Revenue Service Office of Appeals (Appeals Office) failed to hold a meaningful hearing as required by section 6320(b) (Appeals hearing). Petitioner further challenges the merits of a tax deficiency and additions to tax previously redetermined by the Court in a decision entered for his 1990 tax year, and interest assessed thereon. Respondent has moved…

2Cases cited8 opinions

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. Sego v. CommissionerUnited States Tax Court · 2000
  3. Woodral v. CommissionerUnited States Tax Court · 1999
  4. Davis v. CommissionerUnited States Tax Court · 2000
  5. Moore v. CommissionerUnited States Tax Court · 2000

3 more not listed; retrieve them via the Exa API.

3Cited by207 opinions

  1. Robinette v. Comm'rUnited States Tax Court · 2004
  2. Thompson v. CommissionerUnited States Tax Court · 2013
  3. Greene-Thapedi v. Comm'rUnited States Tax Court · 2006
  4. Swanson v. Comm'rUnited States Tax Court · 2003
  5. Van Es v. CommissionerUnited States Tax Court · 2000

202 more not listed; retrieve them via the Exa API.

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