· 11/20/2006
Murphy v. Commissioner of IRS
Citations
- 469 F.3d 27
- 98 A.F.T.R.2d (RIA) 7853
- 2006 U.S. App. LEXIS 28687
- 2006 WL 3350742
How courts have described this case
Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.
- noting that the Supreme Court has consistently so stated and citing United States v. Carlo Bianchi & Co., 373 U.S. 709, 714–15 (1963)
- explaining that the IRS “will not accept a compromise that is less than the reasonable collection value of the case.”
- finding no abuse of discretion when the IRS reached a reasonable conclusion regarding a taxpayer’s ability to pay and, accordingly, rejected an offer in compromise
- finding no abuse of discretion when IRS rejected offer in compromise after reasonably determining that taxpayers could afford more than compromise amount
- explaining IRS \will not accept a compromise that is less than the reasonable collection value of the case\
- “We will only disturb the rejection of [the appellant’s] offer-in-compromise if it represents a clear abuse of discretion in the sense of taxpayer abuse and unfairness by the IRS.”
Source: CourtListener parenthetical corpus (CC0).
Judges: Selya, Howard, Smith
Read full opinion on CourtListenerSourced from CourtListener / Free Law Project (CC0).
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