Legal Opinion

Downing v. Comm'r

United States Tax Court

Decided January 7, 2002No. 2217-00LPublished

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

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. Sego v. CommissionerUnited States Tax Court · 2000
  3. Woodral v. CommissionerUnited States Tax Court · 1999
  4. Katz v. CommissionerUnited States Tax Court · 2000
  5. Estate of Young v. CommissionerUnited States Tax Court · 1983

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