125 T.C. No. 15
UNITED STATES TAX COURT
EDWARD F. MURPHY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10239-03L. Filed December 29, 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
1999. P claims that the SO abused her discretion by
(1) rejecting P’s offer in compromise, based
alternatively on doubt as to collectibility and the
promotion of effective tax administration, and (2)
improperly and prematurely concluding P’s hearing. R
objects to P’s testimony as to reasons he did not pay
his 1992-2001 tax liabilities as they came due and the
SO’s testimony as to entries in her case activity notes
and certain aspects of her handling of the case.
1. Held: P’s testimony is excluded.
2. Held, further, SO’s testimony is admitted as
to meaning of notations and abbreviations in her case
activity report; the remainder of her testimony is
excluded.
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