Iannone v. Comm'r
United States Tax Court
P filed a timely petition for judicial review pursuant to sec. 6330(d)(1)(A), I.R.C., in response to a notice of determination by R to proceed with collection of assessed tax liabilities for 1987, 1989, and 1991. Subsequently, the Court granted respondent's Motion to Dismiss for Lack of Jurisdiction and to Strike as to Taxable Year 1987. Held: For the purpose of this collection proceeding, the Appeals officer agreed to assume that petitioner's 1989 and 1991 tax liabilities…
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P filed a timely petition for judicial review pursuant to sec. 6330(d)(1)(A), I.R.C., in response to a notice of determination by R to proceed with collection of assessed tax liabilities for 1987, 1989, and 1991. Subsequently, the Court granted respondent's Motion to Dismiss for Lack of Jurisdiction and to Strike as to Taxable Year 1987. Held: For the purpose of this collection proceeding, the Appeals officer agreed to assume that petitioner's 1989 and 1991 tax liabilities were discharged in bankruptcy. We will not remand this case for a clearer articulation of the Appeals officer's…
1Opinion of the Court
Nims, Judge:
This case arises from a petition for judicial review filed in response to a “NOTICE OF DETERMINATION CONCERNING COLLECTION ACTIONS(S) UNDER SECTION 6320 AND/OR 6330” (notice of determination). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulations of the parties, with accompanying exhibits, are incorporated herein by this reference. At the time the petition was filed in this case, petitioner resided in Ringwood, New Jersey.
On June…
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- Landry v. CommissionerUnited States Tax Court · 2001
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- In Re Ronald J. Yuhas, Debtor. Thomas J. Orr v. Ronald J. YuhasCourt of Appeals for the Third Circuit · 1997
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