Sal and Ruth Alaniz - Page 1

                                  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                       

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