Legal Opinion

Dutton v. Comm'r

United States Tax Court

Decided February 11, 2004No. 17802-02Published

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

  1. Woods v. CommissionerUnited States Tax Court · 1989
  2. Krause v. CommissionerUnited States Tax Court · 1992
  3. Hildebrand v. CommissionerCourt of Appeals for the Tenth Circuit · 1994
  4. Dorchester Indus. v. Comm'rUnited States Tax Court · 1997
  5. United States v. LaneCourt of Appeals for the Fifth Circuit · 1962

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