Legal Opinion

Savoy v. Comm'r

United States Tax Court

Decided August 12, 2014No. Docket No. 12316-12LUnpublishedCited by 1 opinion

P has a serious and sometimes disabling illness, and did not timely file a return for the 2007 tax year. R prepared a substitute for return pursuant to I.R.C. sec. 6020(b), issued a notice of deficiency, and assessed the tax. Thereafter, R issued P a notice of proposed levy. After an initial administrative hearing, R issued a notice of determination not to sustain the levy for the 2007 tax year.

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P has a serious and sometimes disabling illness, and did not timely file a return for the 2007 tax year. R prepared a substitute for return pursuant to I.R.C. sec. 6020(b), issued a notice of deficiency, and assessed the tax. Thereafter, R issued P a notice of proposed levy. After an initial administrative hearing, R issued a notice of determination not to sustain the levy for the 2007 tax year. The notice of determination placed P in "currently not collectible" status and stated that R would file a notice of lien to protect its interests as creditor. P timely petitioned the Tax Court to…

1Opinion of the Court

GREGORY SCOTT SAVOY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Savoy v. Comm'r

Docket No. 12316-12L

United States Tax Court

T.C. Memo 2014-162; 2014 Tax Ct. Memo LEXIS 160; 108 T.C.M. (CCH) 168;

August 12, 2014, Filed

An appropriate order and decision will be entered for respondent.

P has a serious and sometimes disabling illness, and did not timely file a return for the 2007 tax year. R prepared a substitute for return pursuant to I.R.C. sec. 6020(b), issued a notice of deficiency, and assessed the tax. Thereafter, R issued P a notice of proposed levy. After an initial…

2Cases cited19 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. Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988

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

3Cited by1 opinion

  1. Paulette Etoty v. CommissionerUnited States Tax Court · 2020

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