Edward F. Murphy v. Commissioner of Internal Revenue

Summary

The Tax Court reviewed a settlement officer's determination that the IRS could levy to collect the petitioner's unpaid 1999 tax after rejecting his offer in compromise of $10,000 against a 1992-2001 liability of $275,777. The Court sustained objections to most trial testimony, admitting only the settlement officer's explanation of notations in her case activity report, and held that she did not abuse her discretion in rejecting the offer on both effective-tax-administration and doubt-as-to-collectibility grounds or in closing the hearing after repeated missed deadlines. Decision was entered for respondent.