Boyd v. Comm'r
United States Tax Court
HELD: Petitioner's request for a sec. 6330 hearing suspended the applicable 10-year limitations period for collecting petitioner's Federal income taxes for taxable years 1989 and 1990, and respondent is not time barred from collecting those taxes. HELD, FURTHER, petitioner has failed to show that he paid the subject tax liabilities for taxable years 1991, 1992, 1993, 1996, and 1997. HELD, FURTHER, petitioner's request for a new trial is denied.
1Opinion of the Court
Thornton, Judge:
Petitioner seeks review under section 6330(d) of a determination made by respondent’s Office of Appeals that respondent’s action to collect by levy certain income taxes for 1989, 1990, 1991, 1992, 1993, 1996, and 1997 may proceed. Petitioner contests the levy on grounds that respondent is time barred from collecting taxes for taxable years 1989 and 1990, and that petitioner has already paid the subject tax liabilities for the other years in issue.
Unless otherwise indicated, all section references are to the Internal Revenue Code presently in effect, and all Rule references are…
2Cases cited11 opinions
- Tokarski v. CommissionerUnited States Tax Court · 1986
- Cupp v. CommissionerUnited States Tax Court · 1975
- Davis v. CommissionerUnited States Tax Court · 2000
- Riland v. CommissionerUnited States Tax Court · 1982
- Landry v. CommissionerUnited States Tax Court · 2001
6 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Hoffman v. Comm'rUnited States Tax Court · 2002
- Jordan v. Comm'rUnited States Tax Court · 2010
- Ron Lykins, Inc. v. Comm'rUnited States Tax Court · 2009
- Goff v. CommissionerUnited States Tax Court · 2010
- Severo v. Comm'rUnited States Tax Court · 2007
27 more not listed; retrieve them via the Exa API.