Downing v. Comm'r
United States Tax Court
Petitioners (Ps) filed a return for 1995 in which they correctly reported their tax liability but did not pay the tax owed. Ps included $ 5,000 and an offer in compromise in which they offered to pay that amount in full settlement of the $ 32,561 tax they owed. Respondent (R) misplaced Ps' offer in compromise for about 1 year.
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Petitioners (Ps) filed a return for 1995 in which they correctly reported their tax liability but did not pay the tax owed. Ps included $ 5,000 and an offer in compromise in which they offered to pay that amount in full settlement of the $ 32,561 tax they owed. Respondent (R) misplaced Ps' offer in compromise for about 1 year. R did not accept that offer in compromise or four similar offers in compromise made by Ps because R believed R could collect a substantially larger amount of Ps' 1995 tax liability. R issued to Ps a notice of intent to levy. Ps requested and received a hearing on the…
1Opinion of the Court
BARRY R. DOWNING AND MARY A. DOWNING, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Downing v. Comm'r
No. 2217-00L
United States Tax Court
118 T.C. 22; 2002 U.S. Tax Ct. LEXIS 2; 118 T.C. No. 2;
January 7, 2002., Filed
Respondent's determinations sustained.
Petitioners (Ps) filed a return for 1995 in which they
correctly reported their tax liability but did not pay the tax
owed. Ps included $ 5,000 and an offer in compromise in which
they offered to pay that amount in full settlement of the
$ 32,561 tax they owed.
Respondent (R) misplaced Ps' offer in compromise for about
1 year. R did not…
2Cases cited21 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Woodral v. CommissionerUnited States Tax Court · 1999
- Katz v. CommissionerUnited States Tax Court · 2000
- Estate of Young v. CommissionerUnited States Tax Court · 1983
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