Katz v. Commissioner
United States Tax Court
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
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Woodral v. CommissionerUnited States Tax Court · 1999
- Davis v. CommissionerUnited States Tax Court · 2000
- Moore v. CommissionerUnited States Tax Court · 2000
3 more not listed; retrieve them via the Exa API.
3Cited by207 opinions
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- Swanson v. Comm'rUnited States Tax Court · 2003
- Van Es v. CommissionerUnited States Tax Court · 2000
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