Andre v. Comm'r
United States Tax Court
R issued P a notice of federal tax lien for the taxable years 1996-2000. P then requested a CDP hearing to review R's proposed collection action for the years 1990-2000. R subsequently issued P a notice of intent to levy for the taxable years 1990-1994. R then issued a notice of determination sustaining the proposed collection action, and P timely filed a petition for review.
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R issued P a notice of federal tax lien for the taxable years 1996-2000. P then requested a CDP hearing to review R's proposed collection action for the years 1990-2000. R subsequently issued P a notice of intent to levy for the taxable years 1990-1994. R then issued a notice of determination sustaining the proposed collection action, and P timely filed a petition for review. R then moved to dismiss the petition for taxable years 1990-1994. Held, under sec. 6330(a)(3)(B), a taxpayer has the right "to request a hearing during the 30-day period" before the day of the first levy for a particular…
1Opinion of the Court
ANTHONY AND LENA C. ANDRE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Andre v. Comm'r
No. 2681-04L
United States Tax Court
127 T.C. 68; 2006 U.S. Tax Ct. LEXIS 22; 127 T.C. No. 4;
August 28, 2006, Filed
R issued P a notice of federal tax lien for the taxable years
1996-2000. P then requested a CDP hearing to review R's proposed
collection action for the years 1990-2000. R subsequently issued
P a notice of intent to levy for the taxable years 1990-1994. R
then issued a notice of determination sustaining the proposed
collection action, and P timely filed a petition for review. R
then moved…
2Cases cited8 opinions
- Firstier Mortgage Co. v. Investors Mortgage InsuranceSupreme Court of the United States · 1991
- Craig v. Comm'rUnited States Tax Court · 2002
- Offiler v. CommissionerUnited States Tax Court · 2000
- Lunsford v. Comm'rUnited States Tax Court · 2001
- MOORHOUS v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
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