Mannella v. Comm'r
United States Tax Court
R mailed P a notice of intent to levy and notice of the right to a hearing pursuant to sec. 6330, I.R.C. (notice of intent to levy), on June 4, 2004. On Nov. 1, 2006, P requested relief from joint and several liability under sec. 6015, I.R.C. R denied P's request as untimely. P then petitioned this Court for relief under sec. 6015, I.R.C., and R moved for summary judgment.
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R mailed P a notice of intent to levy and notice of the right to a hearing pursuant to sec. 6330, I.R.C. (notice of intent to levy), on June 4, 2004. On Nov. 1, 2006, P requested relief from joint and several liability under sec. 6015, I.R.C. R denied P's request as untimely. P then petitioned this Court for relief under sec. 6015, I.R.C., and R moved for summary judgment. R argues that P is ineligible for relief under sec. 6015(b), (c), and (f), I.R.C., because she did not request relief within 2 years of R's mailing the notice of intent to levy. P argues that the 2-year limitations period…
1Opinion of the Court
OPINION
Haines, Judge:
This case is before the Court on respondent’s motion for summary judgment. Petitioner brought this action under section 6015 seeking relief from joint and several liability for unpaid taxes.1
Background
Petitioner resided in Pennsylvania at the time her petition was filed.
Petitioner and her husband, Anthony J. Mannella, filed joint Federal income tax returns for the years 1996 through 2000 (years at issue). Because petitioner and Mr. Mannella failed to pay the taxes due for the years at issue,2 respondent issued each of them a separate Final Notice, Notice of Intent to Levy…
2Cases cited14 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Naftel v. CommissionerUnited States Tax Court · 1985
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3Cited by11 opinions
- Pullins v. CommissionerUnited States Tax Court · 2011
- Haag v. Comm'rUnited States Tax Court · 2011
- Torrisi v. Comm'rUnited States Tax Court · 2011
- Denise Mannella v. CommissionerUnited States Tax Court · 2009
- Denise Mannella v. Commissioner IRSCourt of Appeals for the Third Circuit · 2011
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