Legal Opinion
Charles M. Corbalis & Linda J. Corbalis v. Commissioner
United States Tax Court
Decided January 27, 2014No. 8220-13PublishedCited by 1 opinion
1Opinion of the Court
142 T.C. No. 2
UNITED STATES TAX COURT CHARLES M. CORBALIS AND LINDA J. CORBALIS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8220-13. Filed January 27, 2014. Petitioners seek judicial review of Letters 3477 denying their claim for interest suspension under I.R.C. sec. 6404(g) and stating that the determinations are not subject to judicial review under I.R.C. sec. 6404(h). Respondent has moved to dismiss for lack of jurisdiction. Held: The Court has jurisdiction under I.R.C. sec. 6404(h) to review denials of interest suspension under I.R.C. sec. 6404(g). Held,…
2Cases cited29 opinions
- Citizens to Preserve Overton Park, Inc. v. VolpeSupreme Court of the United States · 1971
- Califano v. SandersSupreme Court of the United States · 1977
- Commissioner v. SchleierSupreme Court of the United States · 1995
- Woodral v. CommissionerUnited States Tax Court · 1999
- Hinck v. United StatesSupreme Court of the United States · 2007
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3Cited by1 opinion
- SECC Corp. v. CommissionerUnited States Tax Court · 2014