Legal Opinion

Linda J. Romano-Murphy v. Commissioner

United States Tax Court

Decided May 21, 2019No. 27236-09LUnknown

1Opinion of the Court

152 T.C. No. 16

UNITED STATES TAX COURT LINDA J. ROMANO-MURPHY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 27236-09L. Filed May 21, 2019. On July 26, 2006, R (or the IRS) mailed a Letter 1153, Trust Fund Recovery Penalty Letter, to P, notifying her that she would be subject to the assessment of a penalty under I.R.C. sec. 6672(a). That section imposes a penalty on any person who is responsible for withholding amounts of federal tax and paying them over to the United States and who willfully fails to fulfill these obligations. The penalty is referred to as the…

2Cases cited52 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Morton v. RuizSupreme Court of the United States · 1974
  3. Flora v. United StatesSupreme Court of the United States · 1960
  4. PDK Laboratories Inc. v. United States Drug Enforcement AdministrationCourt of Appeals for the D.C. Circuit · 2004
  5. Naftel v. CommissionerUnited States Tax Court · 1985

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