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.
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