T.C. Memo. 2005-4 UNITED STATES TAX COURT SAL ALANIZ AND RUTH ALANIZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5814-03L. Filed January 11, 2005. Ps filed a petition for judicial review pursuant to sec. 6330, I.R.C., in response to a determination by R to proceed with collection by levy of assessed income tax liabilities, plus penalties and interest, for 1994, 1996, and 1997. Both parties filed motions for summary judgment under Rule 121, Tax Court Rules of Practice and Procedure. Held: R’s rejection of a $2,000 offer in compromise proposed by Ps did not constitute an abuse of discretion. Held, further, R’s motion for summary judgment is granted, and R may proceed with collection of balances due as determined in a Notice Of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. Ps’ motion for summary judgment is denied.Page: 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011