Legal Opinion

Joseph C. Gallagher v. Commissioner

United States Tax Court

Decided June 6, 2018No. 18928-16LUnpublished

1Opinion of the Court

T.C. Memo. 2018-77

UNITED STATES TAX COURT JOSEPH C. GALLAGHER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18928-16L. Filed June 6, 2018. Joseph C. Gallagher, pro se. Kirsten E. Brimer and Daniel C. Munce, for respondent. MEMORANDUM OPINION LAUBER, Judge: In this collection due process (CDP) case, petitioner seeks review pursuant to section 6330(d)(1)1 of the determination by the Internal 1 All statutory references are to the Internal Revenue Code in effect at all rel- evant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. We round…

2Cases cited16 opinions

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  3. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  4. Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
  5. Murphy v. Commissioner of IRSCourt of Appeals for the First Circuit · 2006

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