Perkins v. Comm'r
United States Tax Court
P timely filed his Federal income tax return for 2000 but failed to pay fully the amount reported as due. R increased the Federal income tax liability reported by P on his 2000 return and assessed the increase pursuant to sec. 6213(b)(1), I.R.C. After expiration of the period in which to request abatement of the increased assessment under sec. 6213(b)(2), I.R.C., P appealed the increase in a letter that was forwarded to R's Office of Appeals.
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P timely filed his Federal income tax return for 2000 but failed to pay fully the amount reported as due. R increased the Federal income tax liability reported by P on his 2000 return and assessed the increase pursuant to sec. 6213(b)(1), I.R.C. After expiration of the period in which to request abatement of the increased assessment under sec. 6213(b)(2), I.R.C., P appealed the increase in a letter that was forwarded to R's Office of Appeals. While consideration by Appeals was pending, R issued P a notice of intent to levy to collect the outstanding liability for 2000. P timely requested a…
1Opinion of the Court
ROBERT L. PERKINS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Perkins v. Comm'r
No. 21997-04L
United States Tax Court
129 T.C. 58; 2007 U.S. Tax Ct. LEXIS 26; 129 T.C. No. 7;
September 13, 2007, Filed
P timely filed his Federal income tax return for 2000 but failed to pay fully the amount reported as due. R increased the Federal income tax liability reported by P on his 2000 return and assessed the increase pursuant to sec. 6213(b)(1), I.R.C. After expiration of the period in which to request abatement of the increased assessment under sec. 6213(b)(2), I.R.C., P appealed the…
2Cases cited14 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Davis v. CommissionerUnited States Tax Court · 2000
- Lunsford v. Comm'rUnited States Tax Court · 2001
- Montgomery v. Comm'rUnited States Tax Court · 2004
- Magana v. Comm'rUnited States Tax Court · 2002
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