Headley v. Comm'r
United States Tax Court
The Internal Revenue Service (IRS) issued final notices of intent to levy for a number of taxable years, but P requested an IRS Appeals Office hearing (hearing) under sec. 6330, I.R.C., for only one of these years -- 2000. Upon P's failure to participate in the granted hearing, an IRS Appeals officer made a determination as provided for in sec. 6330, I.R.C., that the IRS could proceed with collection of P's year 2000 income tax liability.
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The Internal Revenue Service (IRS) issued final notices of intent to levy for a number of taxable years, but P requested an IRS Appeals Office hearing (hearing) under sec. 6330, I.R.C., for only one of these years -- 2000. Upon P's failure to participate in the granted hearing, an IRS Appeals officer made a determination as provided for in sec. 6330, I.R.C., that the IRS could proceed with collection of P's year 2000 income tax liability. In due course, R issued a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 regarding that action. P filed a complaint…
1Opinion of the Court
KENNETH N. HEADLEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Headley v. Comm'r
No. 24891-04L
United States Tax Court
T.C. Memo 2007-7; 2007 Tax Ct. Memo LEXIS 6; 93 T.C.M. (CCH) 672;
January 10, 2007, Filed
The Internal Revenue Service (IRS) issued final notices of
intent to levy for a number of taxable years, but P requested an
IRS Appeals Office hearing (hearing) under sec. 6330, I.R.C.,
for only one of these years -- 2000. Upon P's failure to
participate in the granted hearing, an IRS Appeals officer made
a determination as provided for in sec. 6330, I.R.C., that the
IRS could…
2Cases cited7 opinions
- Firstier Mortgage Co. v. Investors Mortgage InsuranceSupreme Court of the United States · 1991
- Craig v. Comm'rUnited States Tax Court · 2002
- Offiler v. CommissionerUnited States Tax Court · 2000
- MOORHOUS v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Van Es v. CommissionerUnited States Tax Court · 2000
2 more not listed; retrieve them via the Exa API.