Legal Opinion

T-Star Engineering and Technical Services, Inc. v. Commissioner

United States Tax Court

Decided September 24, 2018No. 1549-17LUnpublished

1Opinion of the Court

T.C. Memo. 2018-162

UNITED STATES TAX COURT T-STAR ENGINEERING AND TECHNICAL SERVICES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1549-17L. Filed September 24, 2018. Ray S. Kemerer (an officer), for petitioner. Erin K. Neugebaur, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION RUWE, Judge: This collection due process (CDP) case was brought pursuant to sections 6320 and 6330.1 Petitioner challenges respondent’s 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times. -2- [*2] determination to…

2Cases cited7 opinions

  1. Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
  2. Glenn Crain v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1984
  3. United States v. Roy W. CollinsCourt of Appeals for the Tenth Circuit · 1990
  4. Callahan v. Comm'rUnited States Tax Court · 2008
  5. Wnuck v. CommissionerUnited States Tax Court · 2011

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