129 T.C. No. 14
UNITED STATES TAX COURT
JOSEPH GIAMELLI, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23150-04L. Filed October 30, 2007.
P and his wife filed a joint Federal income tax
return for the 2001 tax year reporting a tax due. P
failed to pay the amount due with the joint return. R
accepted the return as filed and assessed the tax
reported therein. Sec. 6201(a)(1), I.R.C. R issued to
P a notice of Federal tax lien, and P filed a request
for a collection review hearing pursuant to sec. 6320,
I.R.C. During the pendency of the collection review
hearing, P and R attempted to negotiate an installment
agreement. R issued a notice of determination
rejecting the proposed installment agreement when P
failed to make estimated tax payments for later tax
years. After filing a petition in this Court for
review of R’s determination, P was killed in an
automobile accident. The estate of P now wishes to be
substituted for P and, for the first time on appeal of
R’s determination, seeks to raise challenges to P’s
underlying liability.
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Last modified: November 10, 2007