People of Michigan v. Vandez Maurice Wright

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that the Court lacks jurisdiction under section 6330 for a claim for refund when the tax liabilities have been satisfied
• explaining that the history of overpayment jurisdiction in deficiency cases would negate any attempt to infer such overpayment jurisdiction in the absence of explicit statutory authority
• finding that the proposed levy action was moot because the Commissioner's offset of the taxpayer's overpayment for a later year against her tax account for the determination year had satisfied her unpaid tax liability in full
• declining to extend our collection due process jurisdiction to determine overpayments or order credits or refunds
• “Inasmuch as the proposed levy is moot, petitioner has no independent basis . to challenge the existence or amount of her underlying tax liability in this proceeding.”
• “An offset under sec- tion 6402 does not constitute a levy action and accordingly is not a collection action that is subject to review in * * * [a] section 6330 proceeding.”

Source: CourtListener parenthetical corpus (CC0).