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· 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 CourtListener

Sourced from CourtListener / Free Law Project (CC0).

This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.