- 13 - call an offset a “taking tantamount to a levy is disingenuous”); cf. sec. 301.6330-1(g)(2) Q&A-G3, Proced. & Admin. Regs. Respondent properly offset petitioner’s 1994 tax liability by crediting refunds from other years in accordance with section 6402. We hold that respondent did not engage in collection activity in violation of section 6015(e)(1)(B). To take account of respondent’s concession, An appropriate order will be issued.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011