Louis A. and Christine Cox - Page 1

                                   126 T.C. No. 13                                    

                               UNITED STATES TAX COURT                                

                     LOUIS A. AND CHRISTINE COX, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos. 21733-03L, 14693-04L.   Filed May 3, 2006.                 

                    Ps’ 1999 and 2000 taxable years became the subject                
               of IRS collection activity through issuance of notices                 
               of intent to levy.  Appeals Officer S thereafter                       
               conducted a simultaneous equivalent hearing with                       
               respect to 1999 and collection hearing pursuant to sec.                
               6330, I.R.C., with respect to 2000.  A principal focus                 
               during that proceeding was the availability of                         
               collection alternatives.  The Appeals Office sustained                 
               the proposed collection activity in November of 2003.                  
               Meanwhile, Ps’ 2001 and 2002 taxable years had likewise                
               become the subject of a notice of intent to levy.  Ps’                 
               request for a hearing regarding these years was                        
               assigned to S, who began his consideration thereof in                  
               early 2004.  Collection alternatives were again a                      
               primary issue raised.  Following a hearing with S, a                   
               notice of determination sustaining the proposed levy                   
               action was issued in July of 2004.                                     

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