Kollar v. Comm'r
United States Tax Court
P filed a joint 1996 Federal income tax return reporting zero income tax liability. Before Dec. 20, 2006, P amended that return and paid the income tax reported on the amended return. P did not pay any statutory interest that had accrued as to that tax. R assessed accrued interest, and P requested from R equitable relief from the assessed interest pursuant to sec. 6015(f), I.R.C.
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P filed a joint 1996 Federal income tax return reporting zero income tax liability. Before Dec. 20, 2006, P amended that return and paid the income tax reported on the amended return. P did not pay any statutory interest that had accrued as to that tax. R assessed accrued interest, and P requested from R equitable relief from the assessed interest pursuant to sec. 6015(f), I.R.C. After R determined that P was not entitled to the requested relief, P petitioned the Court to review that determination under former sec. 6015(e)(1), I.R.C. Relying upon Billings v. Commissioner, 127 T.C. 7 (2006),…
1Opinion of the Court
MARY ANN KOLLAR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Kollar v. Comm'r
No. 15928-05
United States Tax Court
131 T.C. 191; 2008 U.S. Tax Ct. LEXIS 30; 131 T.C. No. 12;
November 25, 2008, Filed
P filed a joint 1996 Federal income tax return reporting zero income tax liability. Before Dec. 20, 2006, P amended that return and paid the income tax reported on the amended return. P did not pay any statutory interest that had accrued as to that tax. R assessed accrued interest, and P requested from R equitable relief from the assessed interest pursuant to sec. 6015(f), I.R.C. After R…
2Cases cited13 opinions
- Connecticut National Bank v. GermainSupreme Court of the United States · 1992
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Naftel v. CommissionerUnited States Tax Court · 1985
- Helvering v. BlissSupreme Court of the United States · 1934
- BUTLER v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
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