Thornberry v. Comm'r
United States Tax Court
The IRS issued notices of intent to levy and notices of Federal tax lien filing to Ps for unpaid income taxes assessed for 2000, 2001, and 2002 and a civil penalty under sec. 6702, I.R.C., assessed for 2007. Ps timely requested an administrative hearing under secs. 6320 and 6330, I.R.C. Ps set forth the grounds for their request in an attachment they downloaded from the Internet.
Read the full summary
The IRS issued notices of intent to levy and notices of Federal tax lien filing to Ps for unpaid income taxes assessed for 2000, 2001, and 2002 and a civil penalty under sec. 6702, I.R.C., assessed for 2007. Ps timely requested an administrative hearing under secs. 6320 and 6330, I.R.C. Ps set forth the grounds for their request in an attachment they downloaded from the Internet. The IRS Office of Appeals (Appeals Office) sent letters to Ps stating that the Appeals Office had determined Ps' request for a hearing consisted of frivolous positions that meet the requirements of sec.…
1Opinion of the Court
OPINION
Dawson, Judge:
This collection case is before the Court on respondent’s motion to dismiss for lack of jurisdiction on the ground that the Internal Revenue Service (IRS) Office of Appeals (the Appeals Office) did not issue petitioners a notice of determination pursuant to section 6320 or 6330.1 Respondent contends that the Appeals Office determined that petitioners’ requests for an administrative hearing in their entirety met the requirements of section 6702(b)(2)(A)(i) or (ii) and, pursuant to section 6330(g), treated the requests as if they were never submitted. Respondent further…
2Cases cited15 opinions
- Bull v. United StatesSupreme Court of the United States · 1935
- Goza v. CommissionerUnited States Tax Court · 2000
- Davis v. CommissionerUnited States Tax Court · 2000
- Craig v. Comm'rUnited States Tax Court · 2002
- Pyo v. CommissionerUnited States Tax Court · 1984
10 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- John Ryskamp v. Commissioner of IRSCourt of Appeals for the D.C. Circuit · 2015
- Alexander v. Comm'rUnited States Tax Court · 2012
- Schlabach v. United StatesUnited States Court of Federal Claims · 2011
- Buczek v. CommissionerUnited States Tax Court · 2014
- Clark v. Comm'rUnited States Tax Court · 2012
6 more not listed; retrieve them via the Exa API.