Legal Opinion

Anthony and Lena C. Andre v. Commissioner

United States Tax Court

Decided August 28, 2006No. 2681-04LUnknown

1Opinion of the Court

127 T.C. No. 4

UNITED STATES TAX COURT ANTHONY AND LENA C. ANDRE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2681-04L. Filed August 28, 2006. R issued P a notice of federal tax lien for the taxable years 1996-2000. P then requested a CDP hearing to review R’s proposed collection action for the years 1990-2000. R subsequently issued P a notice of intent to levy for the taxable years 1990-1994. R then issued a notice of determination sustaining the proposed collection action, and P timely filed a petition for review. R then moved to dismiss the petition for taxable…

2Cases cited8 opinions

  1. Firstier Mortgage Co. v. Investors Mortgage InsuranceSupreme Court of the United States · 1991
  2. Craig v. Comm'rUnited States Tax Court · 2002
  3. Offiler v. CommissionerUnited States Tax Court · 2000
  4. Lunsford v. Comm'rUnited States Tax Court · 2001
  5. MOORHOUS v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001

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