Legal Opinion

Burke v. Comm'r

United States Tax Court

Decided April 12, 2005No. 17684-03LPublishedCited by 22 opinions

R issued to P statutory notices of deficiency for 1993, 1994, 1995, 1996, and 1997. P filed with the Court a petition for redetermination at docket No. 13410-00. By Order and Order of Dismissal and Decision entered Apr. 10, 2002, the Court dismissed the case on the ground P failed properly to prosecute the case. In addition, the Court imposed a penalty on P pursuant to sec. 6673(a), I.R.C. The Court's Decision was affirmed on appeal and became final.

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R issued to P statutory notices of deficiency for 1993, 1994, 1995, 1996, and 1997. P filed with the Court a petition for redetermination at docket No. 13410-00. By Order and Order of Dismissal and Decision entered Apr. 10, 2002, the Court dismissed the case on the ground P failed properly to prosecute the case. In addition, the Court imposed a penalty on P pursuant to sec. 6673(a), I.R.C. The Court's Decision was affirmed on appeal and became final. R issued to P a Final Notice of Intent to Levy and Notice of Your Right to Hearing and a Notice of Federal Tax Lien Filing and Your Right to a…

1Opinion of the Court

Wherry, Judge:

Petitioner invoked the Court's jurisdiction under sections 6320 and 6330 in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 regarding his unpaid Federal income taxes for 1993, 1994, 1995, 1996, and 1997.1 Respondent’s Office of Appeals (Appeals Office) determined that it was appropriate to file a Federal tax lien against petitioner and that petitioner’s unpaid taxes should be collected by levy.

This case was submitted to the Court following a trial. Thereafter, respondent filed a motion to permit levy pursuant to section…

2Cases cited13 opinions

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. Sego v. CommissionerUnited States Tax Court · 2000
  3. Hughes v. United StatesCourt of Appeals for the Ninth Circuit · 1992
  4. Davis v. CommissionerUnited States Tax Court · 2000
  5. Lunsford v. Comm'rUnited States Tax Court · 2001

8 more not listed; retrieve them via the Exa API.

3Cited by22 opinions

  1. Cox v. Comm'rUnited States Tax Court · 2006
  2. Harris v. Comm'rUnited States Tax Court · 2012
  3. Kanofsky v. Comm'rUnited States Tax Court · 2010
  4. Perkins v. Comm'rUnited States Tax Court · 2011
  5. Powell v. Comm'rUnited States Tax Court · 2009

17 more not listed; retrieve them via the Exa API.

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