Isley v. Commissioner
United States Tax Court
P was a founding member of the popular Isley Brothers singing group, which for many years generated substantial income from personal appearances and record sales. P failed to pay Federal income tax on much of that income.
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P was a founding member of the popular Isley Brothers singing group, which for many years generated substantial income from personal appearances and record sales. P failed to pay Federal income tax on much of that income. The Commissioner sought to collect unpaid tax for all but five years within the 1971-95 period by filing proofs of claim in two bankruptcy proceedings (bankruptcies I & II), which resulted in his collection of substantial amounts from P. The United States also obtained P's criminal conviction for tax evasion and willful failure to file with respect to 1997-2002 (conviction…
1Opinion of the Court
Halpern, Judge:
This case is before the Court to review determinations made by the Internal Revenue Service (IRS) Appeals Office (Appeals) in four notices issued to petitioner after a collection due process (CDP) hearing conducted pursuant to sections 6320(b) and (c) and 6330(b) and (c). Together, those determinations sustained (1) respondent’s right to proceed to collect by levy petitioner’s assessed liabilities for 1997 through 2003 and (2) the filing of notices of Federal tax lien (NFTLs) with respect to those years plus 2004 and 2006. In response thereto, petitioner, pursuant to section…
2Cases cited19 opinions
- Morton v. MancariSupreme Court of the United States · 1974
- Goza v. CommissionerUnited States Tax Court · 2000
- Woodral v. CommissionerUnited States Tax Court · 1999
- Giamelli v. Comm'rUnited States Tax Court · 2007
- Richmond Screw Anchor Co. v. United StatesSupreme Court of the United States · 1928
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3Cited by6 opinions
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- Ronald Isley v. CommissionerUnited States Tax Court · 2013
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