Enos v. Comm'r
United States Tax Court
R assessed income tax, interest, and civil fraud liabilities for Ps' 1971 tax year. Ps were involved in the scrap metal business and had a substantial account receivable from Ps' customer M. R issued to M a notice of levy on the account receivable.
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R assessed income tax, interest, and civil fraud liabilities for Ps' 1971 tax year. Ps were involved in the scrap metal business and had a substantial account receivable from Ps' customer M. R issued to M a notice of levy on the account receivable. R and M entered into a payment agreement, whereby M would make 200 weekly payments of $ 1,500 to R. Ps were aware of and participated in the negotiation of the payment agreement between M and R. Ps continued to do business with M and received large payments from M before M was placed in bankruptcy. R filed an original and several amended proofs of…
1Opinion of the Court
JOSEPH F. AND CAROLINE ENOS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Enos v. Comm'r
No. 11630-01L
United States Tax Court
123 T.C. 284; 2004 U.S. Tax Ct. LEXIS 45; 123 T.C. No. 17;
September 27, 2004, Filed
Commissioner's determination that collection should proceed against petitioners sustained.
R assessed income tax, interest, and civil fraud
liabilities for Ps' 1971 tax year. Ps were involved in the scrap
metal business and had a substantial account receivable from Ps'
customer M. R issued to M a notice of levy on the account
receivable. R and M entered into a payment agreement,…
2Cases cited33 opinions
- Northern Pipeline Construction Co. v. Marathon Pipe Line Co.Supreme Court of the United States · 1982
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Cromwell v. County of SacSupreme Court of the United States · 1877
- United States v. Whiting Pools, Inc.Supreme Court of the United States · 1983
- United States v. RodgersSupreme Court of the United States · 1983
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