Perkins v. Comm'r
United States Tax Court
P timely filed his Federal income tax return for 2000 but failed to pay fully the amount reported as due. R increased the Federal income tax liability reported by P on his 2000 return and assessed the increase pursuant to sec. 6213(b)(1), I.R.C. After expiration of the period in which to request abatement of the increased assessment under sec. 6213(b)(2), I.R.C., P appealed the increase in a letter that was forwarded to R's Office of Appeals.
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P timely filed his Federal income tax return for 2000 but failed to pay fully the amount reported as due. R increased the Federal income tax liability reported by P on his 2000 return and assessed the increase pursuant to sec. 6213(b)(1), I.R.C. After expiration of the period in which to request abatement of the increased assessment under sec. 6213(b)(2), I.R.C., P appealed the increase in a letter that was forwarded to R's Office of Appeals. While consideration by Appeals was pending, R issued P a notice of intent to levy to collect the outstanding liability for 2000. P timely requested a…
1Opinion of the Court
Gale, Judge:
Pursuant to section 6330(d)(1),1 petitioner seeks review of respondent’s determination to proceed with a levy to collect petitioner’s Federal income tax liability for taxable year 2000. We conclude that respondent may proceed with collection.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts and the accompanying exhibits are incorporated herein by this reference. Petitioner resided in Wisconsin when he filed the petition in this case.
On April 16, 2001, petitioner timely filed his Federal income tax return for 2000 on a Form 1040, U.S.…
2Cases cited13 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Davis v. CommissionerUnited States Tax Court · 2000
- Lunsford v. Comm'rUnited States Tax Court · 2001
- Montgomery v. Comm'rUnited States Tax Court · 2004
- Magana v. Comm'rUnited States Tax Court · 2002
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