T.C. Memo. 2005-203 UNITED STATES TAX COURT FRANCIS A. MORLINO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18441-03L. Filed August 24, 2005. P asks us to review a determination by R’s settlement officer (SO) that R may proceed with collection by levy of P’s unpaid tax liability for 2001. P claims that the SO abused his discretion by prematurely concluding P’s hearing when P did not provide information by the deadline set by the SO. R objects to P’s testimony as to extenuating circumstances that prevented him from meeting the deadline. 1. Held: P’s testimony is irrelevant since neither he nor his counsel communicated the extenuating circumstances to the SO (nor has P explained his failure to do so). 2. Held, further, R may proceed with collection since the deadline was reasonable.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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