Legal Opinion

Haag v. Comm'r

United States Tax Court

Decided April 19, 2011No. Docket No. 8915-10UnpublishedCited by 4 opinions

P and H filed joint returns and failed to pay tax for 8 years (1985-91 and 1993). R served a notice of proposed levy in September 1999. In 2002 R authorized a collection suit to be brought against P and H in District Court; and P raised as an affirmative defense the claim that she was entitled to relief under I.R.C. sec. 6015(b) and (f). The parties cross-moved for summary judgment on the I.R.C. sec. 6015 issue, and the District Court held in favor of R on the grounds that…

Read the full summary

P and H filed joint returns and failed to pay tax for 8 years (1985-91 and 1993). R served a notice of proposed levy in September 1999. In 2002 R authorized a collection suit to be brought against P and H in District Court; and P raised as an affirmative defense the claim that she was entitled to relief under I.R.C. sec. 6015(b) and (f). The parties cross-moved for summary judgment on the I.R.C. sec. 6015 issue, and the District Court held in favor of R on the grounds that P's assertion of the claim was untimely under I.R.C. sec. 6015(b)(1)(E) and 26 C.F.R. sec. 1.6015-5(b)(1), Income Tax…

1Opinion of the Court

KATHLEEN HAAG, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Haag v. Comm'r

Docket No. 8915-10

United States Tax Court

T.C. Memo 2011-87; 2011 Tax Ct. Memo LEXIS 86; 101 T.C.M. (CCH) 1392;

April 19, 2011, Filed

Haag v. United States, 589 F.3d 43, 2009 U.S. App. LEXIS 27255 (1st Cir. Mass., 2009)

An appropriate order and decision will be entered.

P and H filed joint returns and failed to pay tax for 8 years (1985-91 and 1993). R served a notice of proposed levy in September 1999. In 2002 R authorized a collection suit to be brought against P and H in District Court; and P raised as an…

2Cases cited17 opinions

  1. Allen v. McCurrySupreme Court of the United States · 1980
  2. Montana v. United StatesSupreme Court of the United States · 1979
  3. Commissioner v. SunnenSupreme Court of the United States · 1948
  4. Cromwell v. County of SacSupreme Court of the United States · 1877
  5. Sunshine Anthracite Coal Co. v. AdkinsSupreme Court of the United States · 1940

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

3Cited by4 opinions

  1. Koprowski v. CommissionerUnited States Tax Court · 2012
  2. Haag v. Comm'rUnited States Tax Court · 2014
  3. Kathleen Haag v. CommissionerUnited States Tax Court · 2014
  4. Koprowski v. CommissionerUnited States Tax Court · 2012

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API