Cox v. Comm'r
United States Tax Court
Ps' 1999 and 2000 taxable years became the subject of IRS collection activity through issuance of notices of intent to levy. Appeals Officer S thereafter conducted a simultaneous equivalent hearing with respect to 1999 and collection hearing pursuant to sec. 6330, I.R.C., with respect to 2000. A principal focus during that proceeding was the availability of collection alternatives.
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Ps' 1999 and 2000 taxable years became the subject of IRS collection activity through issuance of notices of intent to levy. Appeals Officer S thereafter conducted a simultaneous equivalent hearing with respect to 1999 and collection hearing pursuant to sec. 6330, I.R.C., with respect to 2000. A principal focus during that proceeding was the availability of collection alternatives. The Appeals Office sustained the proposed collection activity in November of 2003. Meanwhile, Ps' 2001 and 2002 taxable years had likewise become the subject of a notice of intent to levy. Ps' request for a hearing…
1Opinion of the Court
LOUIS A. AND CHRISTINE COX, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Cox v. Comm'r
Nos. 21733-03L, 14693-04L
United States Tax Court
126 T.C. 237; 2006 U.S. Tax Ct. LEXIS 13; 126 T.C. No. 13;
May 3, 2006, Filed
Ps' 1999 and 2000 taxable years became the subject of IRS
collection activity through issuance of notices of intent to
levy. Appeals Officer S thereafter conducted a simultaneous
equivalent hearing with respect to 1999 and collection hearing
pursuant to sec. 6330, I.R.C., with respect to 2000. A principal
focus during that proceeding was the availability of collection
alternative…
2Cases cited23 opinions
- Sego v. CommissionerUnited States Tax Court · 2000
- Woodral v. CommissionerUnited States Tax Court · 1999
- Davis v. CommissionerUnited States Tax Court · 2000
- Lunsford v. Comm'rUnited States Tax Court · 2001
- Katz v. CommissionerUnited States Tax Court · 2000
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