Legal Opinion

Taylor v. Comm'r

United States Tax Court

Decided April 6, 2005No. 14954-03LUnpublishedCited by 3 opinions

P filed a petition for judicial review pursuant to sec. 6330, I.R.C., in response to a determination by R that levy action was appropriate. Held: Because P has advanced groundless complaints in dispute of the notice of intent to levy, R's determination to proceed with collection action is sustained. Held, further, a penalty under sec. 6673, I.R.C., is due from P and is awarded to the United States in the amount of $ 2,500.

1Opinion of the Court

THOMASITA TAYLOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Taylor v. Comm'r

No. 14954-03L

United States Tax Court

T.C. Memo 2005-74; 2005 Tax Ct. Memo LEXIS 74; 89 T.C.M. (CCH) 1017;

April 6, 2005, Filed

Respondent's motion granted.

P filed a petition for judicial review pursuant to sec.

6330, I.R.C., in response to a determination by R that levy

action was appropriate.

Held: Because P has advanced groundless complaints

in dispute of the notice of intent to levy, R's determination to

proceed with collection action is sustained.

Held, further, a penalty under sec. 6673,

I.R.C., is due from…

2Cases cited16 opinions

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. Sego v. CommissionerUnited States Tax Court · 2000
  3. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  4. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  5. Woodral v. CommissionerUnited States Tax Court · 1999

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

3Cited by3 opinions

  1. Calafati v. Comm'rUnited States Tax Court · 2006
  2. Calafati v. Comm'rUnited States Tax Court · 2006
  3. Dominic Calafati v. CommissionerUnited States Tax Court · 2006

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