Clark v. Comm'r
United States Tax Court
R issued a notice of levy on Ps' State tax refund to collect unpaid assessed additions to tax. After Ps requested a hearing under sec. 6330, I.R.C., on the appropriateness of the levy, R determined that the levy was appropriate. Held: The Court has jurisdiction under sec. 6330(d), I.R.C., to review R's determination regarding the levy upon Ps' State tax refund.
1Opinion of the Court
OPINION
Laro, Judge:
Petitioners petitioned the Court under section 6330(d) to review a determination of the Commissioner’s Office of Appeals (Appeals) sustaining respondent’s levy upon their State tax refund.1 Respondent made the levy to collect additions to tax assessed as to petitioners’ 1997 Federal income tax. The sole issue in this Opinion is whether the Court has jurisdiction to review respondent’s determination as to the levy upon petitioners’ State tax refund. We hold that the Court has the requisite jurisdiction.
Background
Petitioners filed their 1997 Federal income tax return…
2Cases cited5 opinions
- American Fire & Casualty Co. v. FinnSupreme Court of the United States · 1951
- Naftel v. CommissionerUnited States Tax Court · 1985
- Raymond v. Comm'rUnited States Tax Court · 2002
- Neely v. CommissionerUnited States Tax Court · 2000
- Dorn v. Comm'rUnited States Tax Court · 2002
3Cited by5 opinions
- Ertz v. Comm'rUnited States Tax Court · 2007
- Kimball v. Comm'rUnited States Tax Court · 2008
- Clark v. Comm'rUnited States Tax Court · 2005
- Herbert and Rosalie Clark v. CommissionerUnited States Tax Court · 2005
- Scott C. Faulk & Leigh S. Faulk v. CommissionerUnited States Tax Court · 2017