Legal Opinion
Joseph Giamelli v. Commissioner
United States Tax Court
Decided October 30, 2007No. 23150-04LUnknown
1Opinion of the Court
129 T.C. No. 14
UNITED STATES TAX COURT JOSEPH GIAMELLI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23150-04L. Filed October 30, 2007. P and his wife filed a joint Federal income tax return for the 2001 tax year reporting a tax due. P failed to pay the amount due with the joint return. R accepted the return as filed and assessed the tax reported therein. Sec. 6201(a)(1), I.R.C. R issued to P a notice of Federal tax lien, and P filed a request for a collection review hearing pursuant to sec. 6320, I.R.C. During the pendency of the collection review hearing, P and R…
2Cases cited39 opinions
- Florida Power & Light Co. v. LorionSupreme Court of the United States · 1985
- 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
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