Kelby v. Comm'r
United States Tax Court
Ps petitioned this Court for review of a notice of determination issued under sec. 6330, I.R.C. Thereafter, the case was remanded to R's Appeals Office three times; each time a supplemental notice of determination was issued. On the third remand, R conceded that Ps' 1989 tax liability was fully satisfied as of April 1990, and the parties agreed that Ps' remaining liabilities would be satisfied by an installment agreement.
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Ps petitioned this Court for review of a notice of determination issued under sec. 6330, I.R.C. Thereafter, the case was remanded to R's Appeals Office three times; each time a supplemental notice of determination was issued. On the third remand, R conceded that Ps' 1989 tax liability was fully satisfied as of April 1990, and the parties agreed that Ps' remaining liabilities would be satisfied by an installment agreement. Although the parties have substantially settled this case, Ps contend that each notice of determination must be separately reviewed in light of their personal and financial…
1Opinion of the Court
RICHARD AND MABEL KELBY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Kelby v. Comm'r
No. 13268-03L
United States Tax Court
130 T.C. 79; 2008 U.S. Tax Ct. LEXIS 6; 130 T.C. No. 6;
April 28, 2008, Filed
Kelby v. Commissioner, T.C. Memo 2005-25, 2005 Tax Ct. Memo LEXIS 26 (T.C., 2005)
Ps petitioned this Court for review of a notice of determination issued under sec. 6330, I.R.C. Thereafter, the case was remanded to R's Appeals Office three times; each time a supplemental notice of determination was issued. On the third remand, R conceded that Ps' 1989 tax liability was fully satisfied…
2Cases cited11 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Lunsford v. Comm'rUnited States Tax Court · 2001
- Freije v. Comm'rUnited States Tax Court · 2005
- Greene-Thapedi v. Comm'rUnited States Tax Court · 2006
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