Medical Practice Solutions, LLC v. Comm'r
United States Tax Court
A single-member LLC failed to pay employment taxes for several periods. Notices of lien and of intent to levy were sent to P, the sole member of the LLC. After hearing under I.R.C. sec. 6330, notices of determination sustaining the lien and proposed levy were sent to "MEDICAL PRACTICE SOLUTIONS LLC CAROLYN BRITTON SOLE MBR", pursuant to sec. 301.7701-3(b), Proced. & Admin. Regs. (check-the-box regulations). P appealed those determinations to this Court.
Read the full summary
A single-member LLC failed to pay employment taxes for several periods. Notices of lien and of intent to levy were sent to P, the sole member of the LLC. After hearing under I.R.C. sec. 6330, notices of determination sustaining the lien and proposed levy were sent to "MEDICAL PRACTICE SOLUTIONS LLC CAROLYN BRITTON SOLE MBR", pursuant to sec. 301.7701-3(b), Proced. & Admin. Regs. (check-the-box regulations). P appealed those determinations to this Court. P and R jointly submitted the case under Rule 122. R moved to reopen the record to admit Forms 4340 to show, for purposes of I.R.C. sec.…
1Opinion of the Court
MEDICAL PRACTICE SOLUTIONS, LLC, CAROLYN BRITTON, SOLE MEMBER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Medical Practice Solutions, LLC v. Comm'r
No. 14664-08L
United States Tax Court
T.C. Memo 2009-214; 2009 Tax Ct. Memo LEXIS 217; 98 T.C.M. (CCH) 57940;
September 16, 2009, Filed
Medical Practice Solutions, LLC v. Comm'r, 132 T.C. 125, 2009 U.S. Tax Ct. LEXIS 6 (2009)
A single-member LLC failed to pay employment taxes for several periods. Notices of lien and of intent to levy were sent to P, the sole member of the LLC. After hearing under I.R.C. sec. 6330, notices of determination…
2Cases cited21 opinions
- Camp v. PittsSupreme Court of the United States · 1973
- Zenith Radio Corp. v. Hazeltine Research, Inc.Supreme Court of the United States · 1971
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
16 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Medical Practice Solutions, LLC v. Comm'rUnited States Tax Court · 2010