Legal Opinion

Baltic v. Comm'r

United States Tax Court

Decided December 27, 2007No. 2826-06LPublished

Bs received a notice of deficiency but filed no petition in this Court. R assessed the tax reported and then sent Bs CDP Notices that he had filed notices of federal tax lien and intended to collect the unpaid tax by levy. Bs requested a CDP hearing, at which they presented an offer-in-compromise based on doubt as to liability.

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Bs received a notice of deficiency but filed no petition in this Court. R assessed the tax reported and then sent Bs CDP Notices that he had filed notices of federal tax lien and intended to collect the unpaid tax by levy. Bs requested a CDP hearing, at which they presented an offer-in-compromise based on doubt as to liability. R's officer who conducted the hearing issued a notice of determination sustaining the filing of the lien and postponing the levy but refused to consider Bs' proposed offer herself. Held: R committed no abuse of discretion in issuing the notice of determination, because…

1Opinion of the Court

PETER P. BALTIC AND KAREN R. BALTIC, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Baltic v. Comm'r

No. 2826-06L

United States Tax Court

129 T.C. 178; 2007 U.S. Tax Ct. LEXIS 38; 129 T.C. No. 19;

December 27, 2007, Filed

Bs received a notice of deficiency but filed no petition in this Court. R assessed the tax reported and then sent Bs CDP Notices that he had filed notices of federal tax lien and intended to collect the unpaid tax by levy. Bs requested a CDP hearing, at which they presented an offer-in-compromise based on doubt as to liability. R's officer who conducted the hearing…

2Cases cited10 opinions

  1. Slodov v. United StatesSupreme Court of the United States · 1978
  2. Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
  3. Moore v. CommissionerUnited States Tax Court · 2000
  4. David and Lynette Kindred v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2006
  5. R. M. Steele v. United StatesCourt of Appeals for the Eighth Circuit · 1960

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