Edward F. Murphy - Page 1

                                   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                     

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