Kreit Mechanical Associates, Inc. v. Commissioner
United States Tax Court
P filed a petition for review pursuant to sec. 6330, I.R.C., in response to R's determination to proceed with collection actions. P sought a collection alternative and submitted an offer-in-compromise. R rejected the offer, concluding that the entire amount due was collectible after R found that a 75-percent discount of P's accounts receivable was inappropriate in valuing P's assets and the offer-in-compromise. Held: R's determination is sustained.
1Opinion of the Court
Wherry, Judge:
This case is before the Court on a petition for review of a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination). 1 Petitioner seeks review of respondent’s determination to proceed with a proposed levy.
The collection action stems from unpaid employment taxes reported on Form 941, Employer’s Quarterly Federal Tax Return, penalties under section 6656, and additions to tax under section 6651(a)(2) with respect to the third quarter of 2005 and all four quarters of 2006. The issue for decision is whether respondent’s…
2Cases cited17 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Woodral v. CommissionerUnited States Tax Court · 1999
12 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Hosie v. Comm'rUnited States Tax Court · 2014
- Brombach v. Comm'rUnited States Tax Court · 2012
- A-Valey Eng'rs, Inc. v. Comm'rUnited States Tax Court · 2012
- Coleman Moore v. CommissionerUnited States Tax Court · 2019
- Hartmann v. Comm'rUnited States Tax Court · 2015
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