Legal Opinion

Giamelli v. Comm'r

United States Tax Court

Decided October 30, 2007No. 23150-04LPublished

P and his wife filed a joint Federal income tax return for the 2001 tax year reporting a tax due. P failed to pay the amount due with the joint return. R accepted the return as filed and assessed the tax reported therein. Sec. 6201(a)(1), I.R.C. R issued to P a notice of Federal tax lien, and P filed a request for a collection review hearing pursuant to sec. 6320, I.R.C.

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P and his wife filed a joint Federal income tax return for the 2001 tax year reporting a tax due. P failed to pay the amount due with the joint return. R accepted the return as filed and assessed the tax reported therein. Sec. 6201(a)(1), I.R.C. R issued to P a notice of Federal tax lien, and P filed a request for a collection review hearing pursuant to sec. 6320, I.R.C. During the pendency of the collection review hearing, P and R attempted to negotiate an installment agreement. R issued a notice of determination rejecting the proposed installment agreement when P failed to make estimated…

1Opinion of the Court

JOSEPH GIAMELLI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Giamelli v. Comm'r

No. 23150-04L

United States Tax Court

129 T.C. 107; 2007 U.S. Tax Ct. LEXIS 33; 129 T.C. No. 14;

October 30, 2007, Filed

P and his wife filed a joint Federal income tax return for the 2001 tax year reporting a tax due. P failed to pay the amount due with the joint return. R accepted the return as filed and assessed the tax reported therein. Sec. 6201(a)(1), I.R.C. R issued to P a notice of Federal tax lien, and P filed a request for a collection review hearing pursuant to sec. 6320, I.R.C. During the…

Also in this document: Concurrence; Dissent · Vasquez; Dissent · Marvel.

2Cases cited39 opinions

  1. Florida Power & Light Co. v. LorionSupreme Court of the United States · 1985
  2. Goza v. CommissionerUnited States Tax Court · 2000
  3. Sego v. CommissionerUnited States Tax Court · 2000
  4. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  5. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992

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