Kendricks v. Comm'r
United States Tax Court
At the conclusion of a collection due process hearing (hearing), R's Appeals Office (Appeals) determined to proceed by levy to collect unpaid assessments of tax. Ps ask us to review that determination.
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At the conclusion of a collection due process hearing (hearing), R's Appeals Office (Appeals) determined to proceed by levy to collect unpaid assessments of tax. Ps ask us to review that determination. Among other errors, Ps claim that Appeals erred in not allowing them to raise at the hearing the tax liabilities underlying the unpaid assessments because they had not had the opportunity to dispute those liabilities in a bankruptcy proceeding instituted by them. 1. Held: The bankruptcy proceeding instituted by petitioners afforded them the opportunity to dispute the underlying liabilities…
1Opinion of the Court
OPINION
Halpern, Judge:
This case is before the Court to review determinations made by respondent’s Appeals Office (Appeals) that respondent may proceed to collect by levy amounts assessed but' unpaid with respect to petitioner Juanita Kendricks’s 1982 through 1984 taxable (calendar) years and petitioners Juanita and Emmanuel Kendricks’ 1985 taxable (calendar) year (collectively, the unpaid assessments).1 We review the determinations pursuant to section 6330(d)(1).2 Petitioners (individually, Mr. or Mrs. Kendricks) assign error to the determinations on the grounds that (1) they did not receive…
2Cases cited13 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cooter & Gell v. Hartmarx Corp.Supreme Court of the United States · 1990
- Goza v. CommissionerUnited States Tax Court · 2000
- Raleigh v. Illinois Department of RevenueSupreme Court of the United States · 2000
- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
8 more not listed; retrieve them via the Exa API.
3Cited by74 opinions
- David and Lynette Kindred v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2006
- Cox v. Comm'rUnited States Tax Court · 2006
- McLaine v. CommissionerUnited States Tax Court · 2012
- Wadleigh v. CommissionerUnited States Tax Court · 2010
- Manko v. Comm'rUnited States Tax Court · 2006
69 more not listed; retrieve them via the Exa API.