Legal Opinion
Borchardt v. Commissioner
District Court, D. Minnesota
Decided October 12, 2004No. Civ. 03-5543 RHKAJBPublishedCited by 3 opinions
1Opinion of the Court
MEMORANDUM OPINION AND ORDER
KYLE, District Judge.
Introduction
Defendant Commissioner of Internal Revenue (the “IRS”) assessed monetary penalties against Plaintiff Terrence J. Bor-chardt for filing frivolous zero-income amended tax returns. After a Collection Due Process Hearing (“CDP Hearing”) between Borchardt and an IRS Office of Appeals settlement officer, the IRS issued a Notice of Determination upholding the penalties. Borchardt then sued the IRS requesting that the Notice of Determination be held invalid because he was not provided with certain documents he had demanded and because he…
2Cases cited8 opinions
- Davis v. CommissionerUnited States Tax Court · 2000
- Nestor v. Comm'rUnited States Tax Court · 2002
- MRCA Information Services v. United StatesDistrict Court, D. Connecticut · 2000
- Rennie v. Internal Revenue ServiceDistrict Court, E.D. California · 2002
- Gillett v. United StatesDistrict Court, W.D. Michigan · 2002
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3Cited by3 opinions
- Lindberg v. Comm'rUnited States Tax Court · 2010
- Schlabach v. United StatesUnited States Court of Federal Claims · 2011
- Gwendolyn L. Kestin v. CommissionerUnited States Tax Court · 2019