Michael Patrick and Debye Lee Leahy - Page 1
129 T.C. No. 8
UNITED STATES TAX COURT
MICHAEL PATRICK AND DEBYE LEE LEAHY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17199-06L. Filed September 17, 2007.
Ps filed a petition pursuant to sec. 6330(d),
I.R.C., challenging R’s determination concerning
collection of Ps’ unpaid income tax for the years 1996-
2000. Ps requested that their case be conducted under
the small tax case procedures authorized by sec.
7463(f)(2), I.R.C., in the case of “an appeal under
section 6330(d)(1)(A) to the Tax Court of a
determination in which the unpaid tax does not exceed
$50,000.” On the date respondent issued the notice of
determination, the total amount of unpaid tax exceeded
$50,000. Nevertheless, Ps contend that because they
dispute less than $50,000 of the underlying tax
liability, this case should proceed under the small tax
case procedures of sec. 7463(f)(2), I.R.C.
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Last modified: November 10, 2007