Legal Opinion

Andre v. Comm'r

United States Tax Court

Decided August 28, 2006No. 2681-04LPublished

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

  1. Firstier Mortgage Co. v. Investors Mortgage InsuranceSupreme Court of the United States · 1991
  2. Craig v. Comm'rUnited States Tax Court · 2002
  3. Offiler v. CommissionerUnited States Tax Court · 2000
  4. Lunsford v. Comm'rUnited States Tax Court · 2001
  5. MOORHOUS v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001

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