Creditguard of Am. v. Comm'r
United States Tax Court
R revoked P's tax-exempt status retroactively to Jan. 1, 2002. In a subsequent deficiency proceeding P executed a stipulated decision document, agreeing to assessment of a deficiency for its 2002 tax year and of underpayment interest on that deficiency "as provided by law." R accrued and assessed interest on the deficiency from the date on which P's 2002 corporate tax return would have been due. When that amount remained unpaid, R began collection action.
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R revoked P's tax-exempt status retroactively to Jan. 1, 2002. In a subsequent deficiency proceeding P executed a stipulated decision document, agreeing to assessment of a deficiency for its 2002 tax year and of underpayment interest on that deficiency "as provided by law." R accrued and assessed interest on the deficiency from the date on which P's 2002 corporate tax return would have been due. When that amount remained unpaid, R began collection action. In a collection due process proceeding, P disputed its underlying liability, arguing that interest can begin accruing no earlier than the…
1Opinion of the Court
CREDITGUARD OF AMERICA, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Creditguard of Am. v. Comm'r
Docket No. 1332-16L
United States Tax Court
2017 U.S. Tax Ct. LEXIS 52; 149 T.C. No. 17;
October 10, 2017, Filed
An appropriate order and decision will be entered.
R revoked P's tax-exempt status retroactively to Jan. 1, 2002. In a subsequent deficiency proceeding P executed a stipulated decision document, agreeing to assessment of a deficiency for its 2002 tax year and of underpayment interest on that deficiency "as provided by law."
R accrued and assessed interest on the deficiency…
2Cases cited9 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
- Helvering v. Morgan's, Inc.Supreme Court of the United States · 1934
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