Giamelli v. Comm'r
United States Tax Court
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
- Florida Power & Light Co. v. LorionSupreme Court of the United States · 1985
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
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