Legal Opinion
Music v. United States
District Court, N.D. Georgia
Decided April 17, 2014No. Civil Action No. 2:12-cv-00220-WCOPublishedCited by 3 opinions
1Opinion of the Court
ORDER
WILLIAM C. O’KELLEY, Senior District Judge.
This is a tax controversy arising from an IRS-imposed levy against plaintiff, Laurie L. Music. Plaintiff, proceeding pro se, claims that the IRS violated 26 U.S.C. § 7433 by failing to send a notice of levy to plaintiffs last known address, which it is required to send pursuant to 26 U.S.C. § 6331(d). The central issue is whether the IRS exercised “reasonable diligence” when the IRS sent a notice of levy to plaintiffs “last known address” even though previous letters sent to that address had been returned undelivered.
On April 1, 2014, the court…
2Cases cited15 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Hartford Underwriters Insurance v. Union Planters Bank, N. A.Supreme Court of the United States · 2000
- Frisch v. CommissionerUnited States Tax Court · 1986
- Eve C.W. Wallin v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Henry G. Pugsley v. Commissioner of Internal Revenue, Joseph T. Rezzonico v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
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3Cited by3 opinions
- Langston v. Internal Revenue Serv. (In re Langston)United States Bankruptcy Court, E.D. California · 2019
- Bosun Tools Co. v. United StatesUnited States Court of International Trade · 2020
- Kristoffer Castro v. Government of GuamDistrict Court, D. Guam · 2026