Legal Opinion

Callahan v. Comm'r

United States Tax Court

Decided February 5, 2008No. 5701-07LPublished

For 2003, Ps submitted Form 1040, U.S. Individual Income Tax Return, and Form 843, Claim for Refund and Request for Abatement, to R. R assessed a frivolous return penalty under sec. 6702, I.R.C., on account of both Ps' 2003 Form 1040 and their 2003 Form 843. After receiving a final notice of intent to levy, Ps requested a hearing under sec. 6330, I.R.C. During their hearing Ps challenged the assessment of the penalties.

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For 2003, Ps submitted Form 1040, U.S. Individual Income Tax Return, and Form 843, Claim for Refund and Request for Abatement, to R. R assessed a frivolous return penalty under sec. 6702, I.R.C., on account of both Ps' 2003 Form 1040 and their 2003 Form 843. After receiving a final notice of intent to levy, Ps requested a hearing under sec. 6330, I.R.C. During their hearing Ps challenged the assessment of the penalties. R's Appeals officer issued a notice of determination denying relief from the penalties. Held: Under sec. 6330(d)(1), I.R.C., as amended by the Pension Protection Act of 2006,…

1Opinion of the Court

DUDLEY JOSEPH CALLAHAN AND MYRNA DUPUY CALLAHAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Callahan v. Comm'r

No. 5701-07L

United States Tax Court

130 T.C. 44; 2008 U.S. Tax Ct. LEXIS 3; 130 T.C. No. 3;

February 5, 2008., Filed

For 2003, Ps submitted Form 1040, U.S. Individual Income Tax Return, and Form 843, Claim for Refund and Request for Abatement, to R. R assessed a frivolous return penalty under sec. 6702, I.R.C., on account of both Ps' 2003 Form 1040 and their 2003 Form 843. After receiving a final notice of intent to levy, Ps requested a hearing under sec. 6330, I.R.C.…

2Cases cited30 opinions

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. Sego v. CommissionerUnited States Tax Court · 2000
  3. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  4. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  5. Naftel v. CommissionerUnited States Tax Court · 1985

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