Legal Opinion

Paulette Etoty v. Commissioner

United States Tax Court

Decided April 20, 2020No. 6871-19LUnpublished

1Opinion of the Court

T.C. Memo. 2020-49

UNITED STATES TAX COURT PAULETTE ETOTY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6871-19L. Filed April 20, 2020. Paulette Etoty, pro se. Valerie Vlasenko and Thomas A. Deamus, for respondent. MEMORANDUM OPINION LAUBER, Judge: In this collection due process (CDP) case, petitioner seeks review of a determination by the Internal Revenue Service (IRS or respond- ent) that a levy on petitioner’s State income tax refund should not be sustained. Respondent has moved for summary judgment under Rule 121, contending that -2- [*2] there are no disputed issues…

2Cases cited13 opinions

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  3. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  4. Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
  5. Murphy v. Commissioner of IRSCourt of Appeals for the First Circuit · 2006

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