Legal Opinion

O'Brien v. Comm'r

United States Tax Court

Decided October 14, 2003No. 9958-02LUnpublishedCited by 1 opinion

P filed a petition for judicial review pursuant to secs. 6320 and 6330, I. R. C., in response to a determination by R to leave in place a filed notice of Federal tax lien. Held : Because the record does not establish an abuse of discretion by R in rejecting P's offer in compromise, R's determination to proceed with collection action is sustained.

1Opinion of the Court

AMY H. O'BRIEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

O'Brien v. Comm'r

No. 9958-02L

United States Tax Court

T.C. Memo 2003-290; 2003 Tax Ct. Memo LEXIS 291; 86 T.C.M. (CCH) 461;

October 14, 2003., Filed

Respondent's determination to proceed with collection sustained.

P filed a petition for judicial review pursuant to secs. 6320 and 6330, I. R. C., in response to a determination by R to leave

in place a filed notice of Federal tax lien.

Held : Because the record does not establish an abuse of

discretion by R in rejecting P's offer in compromise, R's

determination to proceed with…

2Cases cited11 opinions

  1. Aquilino v. United StatesSupreme Court of the United States · 1960
  2. Sego v. CommissionerUnited States Tax Court · 2000
  3. Woodral v. CommissionerUnited States Tax Court · 1999
  4. Magana v. Comm'rUnited States Tax Court · 2002
  5. E. Norman Peterson Marital Trust, Chemical Bank, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1996

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

3Cited by1 opinion

  1. United States v. GibbonsDistrict Court, D. Massachusetts · 2023

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