Kelby v. Comm'r
United States Tax Court
Ps petitioned this Court for review of a notice of determination issued under sec. 6330, I.R.C. Thereafter, the case was remanded to R's Appeals Office three times; each time a supplemental notice of determination was issued. On the third remand, R conceded that Ps' 1989 tax liability was fully satisfied as of April 1990, and the parties agreed that Ps' remaining liabilities would be satisfied by an installment agreement.
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Ps petitioned this Court for review of a notice of determination issued under sec. 6330, I.R.C. Thereafter, the case was remanded to R's Appeals Office three times; each time a supplemental notice of determination was issued. On the third remand, R conceded that Ps' 1989 tax liability was fully satisfied as of April 1990, and the parties agreed that Ps' remaining liabilities would be satisfied by an installment agreement. Although the parties have substantially settled this case, Ps contend that each notice of determination must be separately reviewed in light of their personal and financial…
1Opinion of the Court
OPINION
Haines, Judge:
This collection review case under section 6330 is before the Court on the parties’ cross-motions for entry of decision.1
Background
The parties have substantially agreed on the elements of a decision to be entered. However, they dispute certain aspects of the decision.
The cause of this dispute begins with petitioners’ 1989 return. Petitioners contend that they timely filed their 1989 return in 1990. Respondent disagrees. Respondent’s transcripts indicate that petitioners were issued a substitute for return in 1993 and that respondent filed petitioners’ joint 1989 tax return…
2Cases cited9 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Lunsford v. Comm'rUnited States Tax Court · 2001
- Freije v. Comm'rUnited States Tax Court · 2005
- Greene-Thapedi v. Comm'rUnited States Tax Court · 2006
4 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Hoyle v. CommissionerUnited States Tax Court · 2011
- Johnson v. CommissionerUnited States Tax Court · 2011
- Ginsberg v. Comm'rUnited States Tax Court · 2008
- Churchill v. Comm'rUnited States Tax Court · 2011
- LG Kendrick, LLC v. Comm'rUnited States Tax Court · 2016
22 more not listed; retrieve them via the Exa API.