Legal Opinion

Budish v. Comm'r

United States Tax Court

Decided November 24, 2014No. Docket No. 4243-12LUnpublishedCited by 3 opinions

P, a sculptor who works in cast bronze and sells his artwork through a wholly owned S corporation, filed a Federal income tax return for 2007 on which he self-reported a tax due of $163,928 that he failed to remit with his return. R assessed the unpaid tax plus certain additions to tax and interest, which totaled more than $200,000 and, thereafter, issued a notice of intent to levy.

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P, a sculptor who works in cast bronze and sells his artwork through a wholly owned S corporation, filed a Federal income tax return for 2007 on which he self-reported a tax due of $163,928 that he failed to remit with his return. R assessed the unpaid tax plus certain additions to tax and interest, which totaled more than $200,000 and, thereafter, issued a notice of intent to levy. P requested and received a collection due process (CDP) hearing, which resulted in his agreeing with the Appeals officer on the terms of an installment agreement for full payment of his assessed liability. On the…

1Opinion of the Court

JAMES B. BUDISH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Budish v. Comm'r

Docket No. 4243-12L.

United States Tax Court

T.C. Memo 2014-239; 2014 Tax Ct. Memo LEXIS 237; 108 T.C.M. (CCH) 564;

November 24, 2014, Filed

P, a sculptor who works in cast bronze and sells his artwork through a wholly owned S corporation, filed a Federal income tax return for 2007 on which he self-reported a tax due of $163,928 that he failed to remit with his return. R assessed the unpaid tax plus certain additions to tax and interest, which totaled more than $200,000 and, thereafter, issued a notice of…

2Cases cited13 opinions

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. Woodral v. CommissionerUnited States Tax Court · 1999
  3. Murphy v. Commissioner of IRSCourt of Appeals for the First Circuit · 2006
  4. Murphy v. Comm'rUnited States Tax Court · 2005
  5. Keith Orum and Cherie Orum v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2005

8 more not listed; retrieve them via the Exa API.

3Cited by3 opinions

  1. Deborah P. Richards & Daniel D. Richards v. CommissionerUnited States Tax Court · 2019
  2. Martin D. Kirkley & Sheila G. Kirkley v. CommissionerUnited States Tax Court · 2020
  3. Richard H. Levin & Linda D. Levin v. CommissionerUnited States Tax Court · 2018

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