Dixon v. Commissioner
United States Tax Court
Ps were criminally prosecuted for failure to file individual income tax returns for 1992-95. At the time, Ps were owners, officers, and employees of Tryco Corp., which failed to file employment tax returns and corporate income tax returns during this period.
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Ps were criminally prosecuted for failure to file individual income tax returns for 1992-95. At the time, Ps were owners, officers, and employees of Tryco Corp., which failed to file employment tax returns and corporate income tax returns during this period. As part of a plea agreement with the Department of Justice, Ps agreed that their wrongdoing had inflicted a "tax loss" on the IRS of $61,021 and acknowledged that they could be required to make restitution of this amount. On advice of their attorney they transferred funds to Tryco with instructions that Tryco remit the funds to the IRS.…
1Opinion of the Court
Lauber, Judge:
This is a collection due process (CDP) appeal pursuant to section 6330(d)(1).1 Petitioners challenge a decision by the Internal Revenue Service (IRS or respondent) to levy on their assets for the purpose of collecting their individual income tax liabilities for 1992-95. Petitioners were owners, officers, and employees of Tryco Corp. (Tryco). They challenge the proposed levy on the ground that these liabilities were fully discharged by payments that Tryco made to the IRS in 1999 and 2000.
These cases were tried before Judge Holmes in November 2006, and the facts are detailed in a…
2Cases cited42 opinions
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Goza v. CommissionerUnited States Tax Court · 2000
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Sego v. CommissionerUnited States Tax Court · 2000
- Flora v. United StatesSupreme Court of the United States · 1960
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3Cited by21 opinions
- Jonathan L. Kaplan v. United StatesUnited States Court of Federal Claims · 2013
- Dixon v. Comm'rUnited States Tax Court · 2013
- Terry v. Comm'rUnited States Tax Court · 2016
- David H. Melasky & Audrey Melasky v. CommissionerUnited States Tax Court · 2018
- David J. Chadwick v. CommissionerUnited States Tax Court · 2020
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