Legal Opinion

Dinino v. Comm'r

United States Tax Court

Decided December 10, 2009No. 5596-09LUnpublished

P was assessed trust fund recovery penalties under I.R.C. sec. 6672, and when he failed to pay after notice and demand, the IRS issued a notice of intent to levy. P requested a collection due process (CDP) hearing before the Office of Appeals, indicating that he wanted to submit an offer-in-compromise (OIC). However, P failed to participate in the hearing as scheduled and made no response to a subsequent invitation to submit information.

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P was assessed trust fund recovery penalties under I.R.C. sec. 6672, and when he failed to pay after notice and demand, the IRS issued a notice of intent to levy. P requested a collection due process (CDP) hearing before the Office of Appeals, indicating that he wanted to submit an offer-in-compromise (OIC). However, P failed to participate in the hearing as scheduled and made no response to a subsequent invitation to submit information. Two and a half months later P's representative asked for a conference; but when his request was granted, he asked that the conference be delayed by a month,…

1Opinion of the Court

EUGENE M. DININO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Dinino v. Comm'r

No. 5596-09L

United States Tax Court

T.C. Memo 2009-284; 2009 Tax Ct. Memo LEXIS 288;

December 10, 2009, Filed

P was assessed trust fund recovery penalties under I.R.C. sec. 6672, and when he failed to pay after notice and demand, the IRS issued a notice of intent to levy. P requested a collection due process (CDP) hearing before the Office of Appeals, indicating that he wanted to submit an offer-in-compromise (OIC). However, P failed to participate in the hearing as scheduled and made no response to a…

2Cases cited24 opinions

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. Sego v. CommissionerUnited States Tax Court · 2000
  3. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  4. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  5. Slodov v. United StatesSupreme Court of the United States · 1978

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