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.Page: 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007