Roman v. Comm'r
United States Tax Court
P filed a petition for judicial review pursuant to sec. 6330, I.R.C., in response to a determination by R that levy action is appropriate. Held : Because there was no abuse of discretion by R in rejecting P's offer in compromise, R's determination to proceed with collection action is sustained.
1Opinion of the Court
SCOTT ROMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Roman v. Comm'r
No. 8931-03L
United States Tax Court
T.C. Memo 2004-20; 2004 Tax Ct. Memo LEXIS 20; 87 T.C.M. (CCH) 835;
January 28, 2004, Filed
Respondent's motion for summary judgment granted.
P filed a petition for judicial review pursuant to sec.
6330, I.R.C., in response to a determination by R that levy
action is appropriate.
Held : Because there was no abuse of discretion by R
in rejecting P's offer in compromise, R's determination to
proceed with collection action is sustained.
Kirk T. Karaszkiewicz, for petitioner.
Jack T.…
2Cases cited6 opinions
- Sego v. CommissionerUnited States Tax Court · 2000
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Woodral v. CommissionerUnited States Tax Court · 1999
- E. Norman Peterson Marital Trust, Chemical Bank, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1996
1 more not listed; retrieve them via the Exa API.
3Cited by56 opinions
- Murphy v. Comm'rUnited States Tax Court · 2005
- David and Lynette Kindred v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2006
- Shanley v. Comm'rUnited States Tax Court · 2009
- Cavazos v. Comm'rUnited States Tax Court · 2008
- Orian v. Comm'rUnited States Tax Court · 2010
51 more not listed; retrieve them via the Exa API.