Craig v. Comm'r
United States Tax Court
On Feb. 22, 2001, R mailed to P a final notice of intent to levy (final notice) for 1990, 1991, and 1992. On the same day, R mailed to P a final notice for 1995. On March 17, 2001, P timely requested a hearing under sec. 6330, I.R.C. (Hearing), as to both final notices. Subsequently, R's Appeals officer (A) held with P an "equivalent hearing" under sec. 301.6330-1(i), Proced. & Admin. Regs.
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On Feb. 22, 2001, R mailed to P a final notice of intent to levy (final notice) for 1990, 1991, and 1992. On the same day, R mailed to P a final notice for 1995. On March 17, 2001, P timely requested a hearing under sec. 6330, I.R.C. (Hearing), as to both final notices. Subsequently, R's Appeals officer (A) held with P an "equivalent hearing" under sec. 301.6330-1(i), Proced. & Admin. Regs. A informed P at the equivalent hearing that P was not allowed a Hearing because, A mistakenly believed, P's request for a Hearing was untimely. A later issued to P a decision letter sustaining the proposed…
1Opinion of the Court
OPINION
Laro, Judge:
Petitioner, while residing in Scottsdale, Arizona, petitioned the Court under section 6330(d)(1) to review respondent’s determination as to his proposed levy upon petitioner’s property. Respondent proposed the levy to collect Federal income taxes of approximately $10,656.55 for 1990, $12,192.27 for 1991, $18,437.01 for 1992, and $307.63 for 1995.1 Currently, the case is before the Court on respondent’s motion for summary judgment under Rule 121 and to impose a penalty against petitioner under section 6673(a). Petitioner has filed with the Court a response to respondent’s…
2Cases cited21 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego 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
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3Cited by162 opinions
- Orum v. Comm'rUnited States Tax Court · 2004
- Cooper v. Comm'rUnited States Tax Court · 2010
- David and Lynette Kindred v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2006
- Jones v. CommissionerCourt of Appeals for the Fifth Circuit · 2003
- Gray v. CommissionerUnited States Tax Court · 2012
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