Legal Opinion
Patricia A. Moosally v. Commissioner
United States Tax Court
Decided March 27, 2014No. 6539-12LPublished
1Opinion of the Court
142 T.C. No. 10
UNITED STATES TAX COURT PATRICIA A. MOOSALLY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6539-12L. Filed March 27, 2014. R rejected P’s OIC for P’s trust fund recovery penalties for the periods ending March 31 and September 30, 2000, and P’s income tax liability for her 2008 tax year. P appealed R’s rejection, and R assigned Appeals Officer S to review P’s OIC. R also filed an NFTL for P’s tax liabilities in issue and issued a Letter 3172. P requested a CDP hearing pursuant to I.R.C. sec. 6320, and R assigned Appeals Officer K to conduct P’s CDP…
2Cases cited19 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Naftel v. CommissionerUnited States Tax Court · 1985
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987
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