Legal Opinion

Murphy v. Commissioner of IRS

Court of Appeals for the First Circuit

Decided November 20, 2006No. 06-1109PublishedCited by 305 opinions

1Opinion of the Court

HOWARD, Circuit Judge.

Edward F. Murphy owed federal income taxes in excess of.$250,000 for 1992-2001. He offered to settle this liability by paying $10,000. The Internal Revenue Service (IRS) rejected Murphy’s offer, concluding that he could afford a larger settlement payment. Murphy appealed to the United States Tax Court, which upheld the IRS’s ruling. Murphy now appeals the Tax Court’s decision. We affirm.

I

In April 2002, the IRS issued Murphy a notice of intent to levy on his property to collect on his outstanding income tax liability. Murphy then exercised his right to request a…

2Cases cited11 opinions

  1. United States v. Ilario M.A. ZanninoCourt of Appeals for the First Circuit · 1990
  2. Camp v. PittsSupreme Court of the United States · 1973
  3. United States v. Carlo Bianchi & Co.Supreme Court of the United States · 1963
  4. Town of Norfolk and Town of Walpole v. United States Army Corps of EngineersCourt of Appeals for the First Circuit · 1992
  5. James M. Robinette v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Eighth Circuit · 2006

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3Cited by305 opinions

  1. Giamelli v. Comm'rUnited States Tax Court · 2007
  2. Thompson v. CommissionerUnited States Tax Court · 2013
  3. Weber v. CommissionerUnited States Tax Court · 2012
  4. Christopher Gyorgy v. CIRCourt of Appeals for the Seventh Circuit · 2015
  5. Johnson v. CommissionerUnited States Tax Court · 2011

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