Legal Opinion

First Rock Baptist Church Child Dev. Ctr. v. Comm'r

United States Tax Court

Decided May 18, 2017No. Docket No. 16724-14LPublishedCited by 1 opinion

In an effort to collect P1's outstanding employment tax liabilities for 2007-2010, R issued a Notice of Federal Tax Lien (NFTL) Filing and Your Right to a Hearing. This notice was sent to P1 at its correct address and showed P1's correct taxpayer identification number (TIN). However, the notice showed the addressee as P2, a separately incorporated church with which P1 is affiliated.

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In an effort to collect P1's outstanding employment tax liabilities for 2007-2010, R issued a Notice of Federal Tax Lien (NFTL) Filing and Your Right to a Hearing. This notice was sent to P1 at its correct address and showed P1's correct taxpayer identification number (TIN). However, the notice showed the addressee as P2, a separately incorporated church with which P1 is affiliated. P1 and P2 timely requested a collection due process (CDP) hearing, during which P1 requested that the NFTL be withdrawn and proposed an installment agreement (IA). The settlement officer (SO1) concluded that P1's…

1Opinion of the Court

FIRST ROCK BAPTIST CHURCH CHILD DEVELOPMENT CENTER AND FIRST ROCK BAPTIST CHURCH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

First Rock Baptist Church Child Dev. Ctr. v. Comm'r

Docket No. 16724-14L.

United States Tax Court

2017 U.S. Tax Ct. LEXIS 18; 148 T.C. No. 17;

May 18, 2017, Filed

An appropriate order and decision will be entered for respondent.

In an effort to collect P1's outstanding employment tax liabilities for 2007-2010, R issued a Notice of Federal Tax Lien (NFTL) Filing and Your Right to a Hearing. This notice was sent to P1 at its correct address and showed P1's…

2Cases cited16 opinions

  1. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  2. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  3. Giamelli v. Comm'rUnited States Tax Court · 2007
  4. Keith Orum and Cherie Orum v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2005
  5. Orum v. Comm'rUnited States Tax Court · 2004

11 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Vigon v. Comm'rUnited States Tax Court · 2017

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