Haag v. Comm'r
United States Tax Court
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…
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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
- Allen v. McCurrySupreme Court of the United States · 1980
- Montana v. United StatesSupreme Court of the United States · 1979
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Cromwell v. County of SacSupreme Court of the United States · 1877
- 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
- Koprowski v. CommissionerUnited States Tax Court · 2012
- Haag v. Comm'rUnited States Tax Court · 2014
- Kathleen Haag v. CommissionerUnited States Tax Court · 2014
- Koprowski v. CommissionerUnited States Tax Court · 2012