Cavazos v. Comm'r
United States Tax Court
P filed a Federal income tax return reporting tax due for the year 2002, but did not fully pay the liability. In 2005 P submitted to R an Offer-in-Compromise (OIC) as to his 2002 liability, which R rejected because P had not complied with all return-filing requirements. R issued a notice of intent to levy, and P requested a hearing under I.R.C. sec. 6330. During the hearing P conceded that he was not current with all his filing requirements.
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P filed a Federal income tax return reporting tax due for the year 2002, but did not fully pay the liability. In 2005 P submitted to R an Offer-in-Compromise (OIC) as to his 2002 liability, which R rejected because P had not complied with all return-filing requirements. R issued a notice of intent to levy, and P requested a hearing under I.R.C. sec. 6330. During the hearing P conceded that he was not current with all his filing requirements. P also failed to propose any collection alternatives, other than his previously rejected OIC, or to provide R with requested financial information. R's…
1Opinion of the Court
DAVID CAVAZOS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Cavazos v. Comm'r
No. 28664-07L
United States Tax Court
T.C. Memo 2008-257; 2008 Tax Ct. Memo LEXIS 256; 96 T.C.M. (CCH) 341;
November 17, 2008, Filed
P filed a Federal income tax return reporting tax due for the year 2002, but did not fully pay the liability. In 2005 P submitted to R an Offer-in-Compromise (OIC) as to his 2002 liability, which R rejected because P had not complied with all return-filing requirements. R issued a notice of intent to levy, and P requested a hearing under I.R.C. sec. 6330. During the hearing P…
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