Enos v. Comm'r
United States Tax Court
R assessed income tax, interest, and civil fraud liabilities for Ps' 1971 tax year. Ps were involved in the scrap metal business and had a substantial account receivable from Ps' customer M. R issued to M a notice of levy on the account receivable.
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R assessed income tax, interest, and civil fraud liabilities for Ps' 1971 tax year. Ps were involved in the scrap metal business and had a substantial account receivable from Ps' customer M. R issued to M a notice of levy on the account receivable. R and M entered into a payment agreement, whereby M would make 200 weekly payments of $ 1,500 to R. Ps were aware of and participated in the negotiation of the payment agreement between M and R. Ps continued to do business with M and received large payments from M before M was placed in bankruptcy. R filed an original and several amended proofs of…
1Opinion of the Court
OPINION
Wells, Judge:
The petition in the instant case was filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination).1 In the notice of determination, respondent determined that collection should proceed against petitioners to collect a liability for accrued interest on petitioners’ tax liabilities for 1971.
The issues to be decided are as follows:
1. Whether respondent’s issuance of a notice of levy on an account receivable due petitioners from a customer satisfied petitioners’ original tax liability for 1971 that was…
2Cases cited32 opinions
- Northern Pipeline Construction Co. v. Marathon Pipe Line Co.Supreme Court of the United States · 1982
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Cromwell v. County of SacSupreme Court of the United States · 1877
- United States v. Whiting Pools, Inc.Supreme Court of the United States · 1983
- United States v. RodgersSupreme Court of the United States · 1983
27 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Zapara v. Comm'rUnited States Tax Court · 2005
- Frank Sawyer Trust of May 1992 v. Comm'rUnited States Tax Court · 2009
- Ian Michael Stead Belinda A. Stead v. United StatesCourt of Appeals for the Ninth Circuit · 2005
- Enos v. Comm'rUnited States Tax Court · 2004
- Frank Sawyer Trust of May 1992 v. Comm'rUnited States Tax Court · 2009
5 more not listed; retrieve them via the Exa API.