Legal Opinion
Wells v. Commissioner
Court of Appeals for the Ninth Circuit
Decided August 20, 2004No. 03-73821; IRS No. 163-OILPublishedCited by 4 opinions
1Opinion of the Court
MEMORANDUM**
William G. Wells appeals pro se the Tax Court’s decision upholding the Commissioner’s determination to proceed with a levy to collect Wells’ unpaid 1991 and 1992 federal income taxes totaling $2.25 million. We have jurisdiction pursuant to 26 U.S.C. § 7482. We review de novo the Tax Court’s conclusions of law, and review for clear error its factual findings. Kelley v. C.I.R., 45 F.3d 348, 350 (9th Cir.1995). We affirm.
Wells’ contention that the Tax Court should have remanded his case to the In*441ternal Revenue Service’s Office of Appeals fails because he did not demonstrate that he…
2Cases cited2 opinions
- Alexander Shokai, Inc. Edward Alexander Estelle Alexander v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1994
- David M. Kelley David M. Kelley, Estate of Nancy I. Kelley, Deceased v. Commissioner Internal Revenue Service, David M. Kelley Mary L. Kelley v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
3Cited by4 opinions
- Churchill v. Comm'rUnited States Tax Court · 2011
- Kehoe v. Comm'rUnited States Tax Court · 2013
- Macdonald v. Comm'rUnited States Tax Court · 2014
- Michael J. Kehoe and Karen D. Kehoe v. CommissionerUnited States Tax Court · 2013