Brombach v. Commissioner

T.C. Memo. 2012-265 (2012)

From our private database of 45,900+ case briefs, written and edited by humans—never with AI.

Brombach v. Commissioner

United States Tax Court
T.C. Memo. 2012-265 (2012)

Facts

The Internal Revenue Service (IRS) (defendant) assessed deficiencies against Thomas Brombach (plaintiff) attributable to several taxable years. Brombach negotiated a settlement before the United States Tax Court whereby he agreed to pay $60,000 plus interest. Several years passed in which Brombach failed to pay out the settlement. Brombach’s liability grew to $152,000 because of interest, and the IRS filed a tax lien against all of Brombach’s assets. Brombach sought a collection due-process hearing with an IRS appeals officer. Brombach determined that his own reasonable collection potential was $28,000 and offered to compromise his tax debt for that amount. The appeals officer rejected Brombach’s offer, having calculated Brombach’s reasonable collection potential to be over $113,000. Brombach filed a petition in the Tax Court seeking a ruling that the IRS’s rejection of his offer was an abuse of discretion. The Tax Court held a trial and determined that Brombach had used valuation techniques that substantially undercalculated his reasonable collection potential. The Tax Court also determined that the IRS appeals officer had, in some cases, erroneously overestimated the value of certain items. Ultimately, the Tax Court found that Brombach’s actual reasonable collection potential was about $73,000.

Rule of Law

Issue

Holding and Reasoning (Holmes, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 742,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 742,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 45,900 briefs, keyed to 984 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 742,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 45,900 briefs - keyed to 984 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership