Johnson v. Commissioner
United States Tax Court
P had taxable income of $1.7 million in 1999 and $1.8 million in 2000. P filed income tax returns for those years in 2002 but paid no income tax.
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P had taxable income of $1.7 million in 1999 and $1.8 million in 2000. P filed income tax returns for those years in 2002 but paid no income tax. The Internal Revenue Service (IRS) assessed tax of $514,164 for 1999 and $565,268 for 2000 and then served on P notice of the filing of a notice of Federal tax lien (NFTL) and a notice of proposed levy to collect P's liabilities that (with interest and penalties) totaled $1,586,952.45. P requested a collection due process (CDP) hearing, during which he proposed an offer-in-compromise (OIC), which he amended several times during 2008 and 2009 while…
1Opinion of the Court
OPINION
Gustafson, Judge-.
This is an appeal, pursuant to section 6330(d)(1), 1 by which petitioner Stephen Johnson seeks this Court’s review of a determination by the Office of Appeals of the Internal Revenue Service (irs) to reject Mr. Johnson’s proposed offer-in-compromise (OIC) and to sustain the filing of a notice of Federal tax lien (nftl) and notice of intent to levy, in order to collect Mr. Johnson’s unpaid Federal income taxes for tax years 1999 and 2000. That determination was made after the Office of Appeals had conducted a collection due process (cdp) hearing pursuant to section…
2Cases cited17 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Sego v. CommissionerUnited States Tax Court · 2000
- Baltimore & Ohio Railroad v. United StatesSupreme Court of the United States · 1923
- Murphy v. Commissioner of IRSCourt of Appeals for the First Circuit · 2006
12 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Johnson v. CommissionerCourt of Appeals for the D.C. Circuit · 2013
- Reed v. CommissionerUnited States Tax Court · 2013
- Bergdale v. Comm'rUnited States Tax Court · 2014
- Brombach v. Comm'rUnited States Tax Court · 2012
- Hinerfeld v. CommissionerUnited States Tax Court · 2012
18 more not listed; retrieve them via the Exa API.