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