Greene-Thapedi v. Comm'r
United States Tax Court
In her original petition, P challenged R's notice of determination sustaining a proposed levy to collect P's 1992 income tax. She contended, among other things, that R had failed to make a timely assessment of her 1992 tax liabilities and had included excessive interest accruals in her 1992 balance due; she sought a refund of certain amounts previously paid with respect to her 1992 account.
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In her original petition, P challenged R's notice of determination sustaining a proposed levy to collect P's 1992 income tax. She contended, among other things, that R had failed to make a timely assessment of her 1992 tax liabilities and had included excessive interest accruals in her 1992 balance due; she sought a refund of certain amounts previously paid with respect to her 1992 account. After the petition was filed, P's 1992 balance due was eliminated by R's offset of P's 1999 overpayment, pursuant to sec. 6402(a), I.R.C. P amended her petition in the Tax Court, seeking an increased…
1Opinion of the Court
OPINION
Thornton, Judge:
Pursuant to section 6330(d), petitioner seeks review of respondent’s determination to proceed with a proposed levy.1
Background
When she petitioned this Court, petitioner resided in Chicago, Illinois.
Stipulated Decision for 1992 Taxable Year
On June 5, 1997, in a prior deficiency proceeding involving petitioner’s 1992 taxable year, this Court entered a stipulated decision that petitioner had a $10,195 deficiency in income tax due but owed no additions to tax or penalties. The parties stipulated that interest would be assessed as provided by law and that effective upon…
2Cases cited19 opinions
- North Carolina v. RiceSupreme Court of the United States · 1971
- Commissioner v. LundySupreme Court of the United States · 1996
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Davis v. CommissionerUnited States Tax Court · 2000
- Katz v. CommissionerUnited States Tax Court · 2000
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3Cited by81 opinions
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- Weber v. CommissionerUnited States Tax Court · 2012
- Gray v. CommissionerUnited States Tax Court · 2012
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