Hinerfeld v. Commissioner
United States Tax Court
R issued to P a final notice of intent to levy with regard to P's unpaid trust fund recovery penalties totaling $471,696. P timely requested a collection due process (CDP) hearing with the Office of Appeals (Appeals) and submitted to Appeals an offer-in-compromise (OIC) of $10,000, followed by an amended OIC of $74,857. The settlement officer assigned to the case recommended that the amended OIC be accepted and submitted the matter to R's Area Counsel for review in…
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R issued to P a final notice of intent to levy with regard to P's unpaid trust fund recovery penalties totaling $471,696. P timely requested a collection due process (CDP) hearing with the Office of Appeals (Appeals) and submitted to Appeals an offer-in-compromise (OIC) of $10,000, followed by an amended OIC of $74,857. The settlement officer assigned to the case recommended that the amended OIC be accepted and submitted the matter to R's Area Counsel for review in accordance with I.R.C. sec. 7122(b). Upon review, Area Counsel discovered that P and his wife were named as defendants in a…
1Opinion of the Court
Gale, Judge:
Pursuant to section 6330(d), Norman Hinerfeld (petitioner) seeks review of respondent’s determination to proceed with a levy to collect petitioner’s unpaid trust fund recovery penalties (trust fund penalties), assessed pursuant to section 6672, for the quarterly periods ended September 30 and December 31, 2002, March 31, September 30, and December 31, 2003, and June 30, 2004. The issues for decision are: (1) whether respondent’s Office of Appeals (Appeals) and Area Counsel in the Small Business/Self Employed Division of the Office of Chief Counsel (Area Counsel) engaged in…
2Cases cited10 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Watt v. AlaskaSupreme Court of the United States · 1981
- Sego v. CommissionerUnited States Tax Court · 2000
- Giamelli v. Comm'rUnited States Tax Court · 2007
- Millsap v. CommissionerUnited States Tax Court · 1988
5 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Norman Hinerfeld v. CommissionerUnited States Tax Court · 2019
- Norman Hinerfeld v. CommissionerUnited States Tax Court · 2019