Legal Opinion
Leonard L. Best & Evelyn R. Best v. Commissioner
United States Tax Court
Decided April 28, 2014No. 26662-10LUnpublished
1Opinion of the Court
T.C. Memo. 2014-72
UNITED STATES TAX COURT LEONARD L. BEST AND EVELYN R. BEST, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 26662-10L. Filed April 28, 2014. We review R's decision to proceed with collection of Ps' unpaid income tax. Held: Appeals officer did not abuse her discretion in relying on transcripts to verify that Ps' unpaid tax had been properly assessed. Held, further, documents provided to Ps satisfied R's obligation to provide them with records of assessment for the unpaid tax. Held, further, I.R.C. sec. 6673(a)(1) sanction imposed. Held, further, Ps'…
2Cases cited18 opinions
- Bull v. United StatesSupreme Court of the United States · 1935
- Sego v. CommissionerUnited States Tax Court · 2000
- Norman E. Coleman v. Commissioner of Internal Revenue, Gary Holder v. Secretary of the Treasury and United States of AmericaCourt of Appeals for the Seventh Circuit · 1986
- Craig v. Comm'rUnited States Tax Court · 2002
- Nestor v. Comm'rUnited States Tax Court · 2002
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