Orum v. Comm'r
United States Tax Court
Ps filed joint Federal income tax returns for 1998 and 1999 but did not make full payment of the tax liabilities. On June 23, 2000, R sent Ps by certified mail a Notice of Intent to Levy and Notice of Your Right to a Hearing for 1998. Ps did not file a sec. 6330, I.R.C., hearing request in response to this notice.
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Ps filed joint Federal income tax returns for 1998 and 1999 but did not make full payment of the tax liabilities. On June 23, 2000, R sent Ps by certified mail a Notice of Intent to Levy and Notice of Your Right to a Hearing for 1998. Ps did not file a sec. 6330, I.R.C., hearing request in response to this notice. On Dec. 14, 2001, R sent Ps a Notice of Intent to Levy and Notice of Your Right to a Hearing for 1998 and 1999. P sent R a sec. 6330, I.R.C., hearing request dated Dec. 31, 2001, for 1998 and 1999. In February 2002, Ps submitted an offer-in-compromise. R rejected the request on the…
1Opinion of the Court
OPINION
Haines, Judge:
Respondent sent petitioner Keith Orum (Mr. Orum) and petitioner Cherie Orum (Mrs. Orum) a Decision Letter Concerning Equivalent Hearing Under Section 6320 and/or 6330 (decision letter) for 1998 and a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination) for 1999.
The issues for decision are: (1) Whether the Court lacks jurisdiction under section 6330(d)(1)1 with regard to 1998; and (2) whether there was an abuse of discretion in the determination that the proposed collection action for 1999 should be sustained.
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2Cases cited11 opinions
- Lunsford v. Comm'rUnited States Tax Court · 2001
- Craig v. Comm'rUnited States Tax Court · 2002
- Offiler v. CommissionerUnited States Tax Court · 2000
- Abeles v. CommissionerUnited States Tax Court · 1988
- Nicklaus v. Comm'rUnited States Tax Court · 2001
6 more not listed; retrieve them via the Exa API.
3Cited by110 opinions
- Giamelli v. Comm'rUnited States Tax Court · 2007
- Speltz v. Comm'rUnited States Tax Court · 2005
- Cox v. Comm'rUnited States Tax Court · 2006
- McLaine v. CommissionerUnited States Tax Court · 2012
- Pough v. Comm'rUnited States Tax Court · 2010
105 more not listed; retrieve them via the Exa API.