Legal Opinion

Keller Tank Services II, Inc. v. Commissioner

Court of Appeals for the Tenth Circuit

Decided April 20, 2017No. 16-9001PublishedCited by 39 opinions

1Opinion of the Court

ORDER

This matter is before us on Appellee’s Motion to Amend Opinion to Clarify Authority of IRS Office of Appeals over Rescission of I.R.C. § 6707A Penalties. Upon careful consideration, the motion is granted. The court’s February 21, 2017 opinion is withdrawn and replaced by the attached revised opinion.

MATHESON, Circuit Judge.

In this appeal, we address whether a taxpayer may challenge a tax penalty in a Collection Due Process hearing (“CDP hearing”) after already having challenged the penalty in the Appeals Office of the Internal Revenue Service (“IRS”).

Keller Tank Services II, Inc.…

2Cases cited48 opinions

  1. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  2. Immigration & Naturalization Service v. Cardoza-FonsecaSupreme Court of the United States · 1987
  3. Robinson v. Shell Oil Co.Supreme Court of the United States · 1997
  4. Lewis v. Continental Bank Corp.Supreme Court of the United States · 1990
  5. Taylor v. SturgellSupreme Court of the United States · 2008

43 more not listed; retrieve them via the Exa API.

3Cited by39 opinions

  1. DTC Energy Grp., Inc. v. HirschfeldCourt of Appeals for the Tenth Circuit · 2018
  2. Our Country Home Enterprises, Inc. v. CommissionerCourt of Appeals for the Seventh Circuit · 2017
  3. Estate of Robert C. Duncan v. CIRCourt of Appeals for the Fifth Circuit · 2018
  4. William Canada, Jr. v. USA (IRS)Court of Appeals for the Fifth Circuit · 2020
  5. William F. Sandoval Irrevocable Trust v. Taylor (In Re Taylor)Court of Appeals for the Tenth Circuit · 2018

34 more not listed; retrieve them via the Exa API.

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