Ballard v. Comm'r
United States Tax Court
P filed a petition and motion to restrain assessment on the same date. As a basis for his motion to restrain assessment, P asserts that R instructed P's employer to change the withholding status on P's Form W-4, Employees Withholding Allowance Certificate, without providing P a remedy to challenge R's actions.
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P filed a petition and motion to restrain assessment on the same date. As a basis for his motion to restrain assessment, P asserts that R instructed P's employer to change the withholding status on P's Form W-4, Employees Withholding Allowance Certificate, without providing P a remedy to challenge R's actions. P asserts that R's instructions to P's employer constitute a collection action and that R failed to comply with the provisions of sec. 6330(a), I.R.C.1All section references are to the Internal Revenue Code, as amended, unless otherwise indicated, and all Rule references are to the Tax…
1Opinion of the Court
JOHN BALLARD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Ballard v. Comm'r
No. 4307-07L
United States Tax Court
T.C. Memo 2007-159; 2007 Tax Ct. Memo LEXIS 161; 93 T.C.M. (CCH) 1394;
June 20, 2007, Filed
P filed a petition and motion to restrain assessment on the same date. As a basis for his motion to restrain assessment, P asserts that R instructed P's employer to change the withholding status on P's Form W-4, Employees Withholding Allowance Certificate, without providing P a remedy to challenge R's actions. P asserts that R's instructions to P's employer constitute a collection…
2Cases cited10 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Offiler v. CommissionerUnited States Tax Court · 2000
- Keith Orum and Cherie Orum v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2005
- Orum v. Comm'rUnited States Tax Court · 2004
- Wheeler's Peachtree Pharmacy, Inc. v. CommissionerUnited States Tax Court · 1960
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3Cited by4 opinions
- Cleveland v. CommissionerCourt of Appeals for the Seventh Circuit · 2010
- Robert Cleveland v. CIRCourt of Appeals for the Seventh Circuit · 2010
- Tuka v. CommissionerCourt of Appeals for the Third Circuit · 2009
- Tuka v. CommissionerCourt of Appeals for the Third Circuit · 2009