Mason v. Comm'r
United States Tax Court
P is majority owner and principal officer of C, which failed to pay employment taxes. R mailed a notice of intent to assess sec. 6672, I.R.C., trust fund penalties to P at P's last known address. P did not receive R's notice and the penalties were assessed. R notified P of the intent to file a notice of Federal tax lien with respect to the penalties. P administratively appealed and also filed a request to abate the penalties.
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P is majority owner and principal officer of C, which failed to pay employment taxes. R mailed a notice of intent to assess sec. 6672, I.R.C., trust fund penalties to P at P's last known address. P did not receive R's notice and the penalties were assessed. R notified P of the intent to file a notice of Federal tax lien with respect to the penalties. P administratively appealed and also filed a request to abate the penalties. After administrative review of R's decision to file a lien, R determined to proceed with the lien filing. P's abatement request was also denied. P appealed both…
1Opinion of the Court
OPINION
Gerber, Judge:
This case arises from a petition for judicial review filed in response to a Notice of Determination Concerning Collection Actions(s) Under Section 6320 and/or 6330 (notice of determination) issued to petitioner Mattie Marie Mason.1 The overall question is whether respondent may proceed with the collection action. The answer depends upon whether petitioner is liable for trust fund penalties assessed against her as a responsible person for failure to collect and pay over withholding taxes of New Life Perinatal Health Care Services, Inc. (New Life), for tax periods ended…
2Cases cited29 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Slodov v. United StatesSupreme Court of the United States · 1978
- Giamelli v. Comm'rUnited States Tax Court · 2007
- Mazo v. United StatesCourt of Appeals for the Fifth Circuit · 1979
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3Cited by45 opinions
- Weber v. CommissionerUnited States Tax Court · 2012
- Thornberry v. Comm'rUnited States Tax Court · 2011
- Orian v. Comm'rUnited States Tax Court · 2010
- Thompson v. Comm'rUnited States Tax Court · 2012
- Byrne v. United StatesUnited States Court of Federal Claims · 2016
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