Legal Opinion
James N. Gaunt & Lillian Gaunt v. Commissioner
United States Tax Court
Decided June 6, 2018No. 17513-15LUnpublished
1Opinion of the Court
T.C. Memo. 2018-78
UNITED STATES TAX COURT JAMES N. GAUNT AND LILLIAN GAUNT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17513-15L. Filed June 6, 2018. Wayne J. King, for petitioners. Scott A. Hovey and Jacob Russin, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LAUBER, Judge: The posture of this collection due process (CDP) case is somewhat unusual. Petitioners have conceded that the Internal Revenue Service (IRS or respondent) did not abuse its discretion in sustaining a notice of intent to levy relating to their 2008, 2009, and 2010 tax years. Instead,…
2Cases cited20 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Goza v. CommissionerUnited States Tax Court · 2000
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