Dutton v. Comm'r
United States Tax Court
P submitted a request for relief from joint and several liability. P subsequently submitted an offer in compromise, which R accepted. Before the offer was accepted, R sent P a letter explaining that it was proposed that P be granted relief under sec. 6015(c), I.R.C., and that P would be entitled to a refund.
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P submitted a request for relief from joint and several liability. P subsequently submitted an offer in compromise, which R accepted. Before the offer was accepted, R sent P a letter explaining that it was proposed that P be granted relief under sec. 6015(c), I.R.C., and that P would be entitled to a refund. After accepting the offer, R sent P a notice of determination denying relief from joint and several liability under former sec. 6013(e), I.R.C., and sec. 6015(b), (c), and (f), I.R.C. P petitioned the Court under sec. 6015(e)(1), I.R.C. P argues that the statement that P would be entitled…
1Opinion of the Court
JOSEPH DUTTON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Dutton v. Comm'r
No. 17802-02
United States Tax Court
122 T.C. 133; 2004 U.S. Tax Ct. LEXIS 6; 122 T.C. No. 7;
February 11, 2004, Filed
Petitioner barred from seeking relief from joint and several liability.
P submitted a request for relief from joint and several
liability. P subsequently submitted an offer in compromise,
which R accepted. Before the offer was accepted, R sent P a
letter explaining that it was proposed that P be granted relief
under sec. 6015(c), I.R.C., and that P would be entitled to a
refund. After accepting the…
2Cases cited14 opinions
- Woods v. CommissionerUnited States Tax Court · 1989
- Krause v. CommissionerUnited States Tax Court · 1992
- Hildebrand v. CommissionerCourt of Appeals for the Tenth Circuit · 1994
- Dorchester Indus. v. Comm'rUnited States Tax Court · 1997
- United States v. LaneCourt of Appeals for the Fifth Circuit · 1962
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