Vosters v. United States
United States Bankruptcy Court for the Northern District of California
89-1 USTC ¶ 9387 (1989)
- Written by Steven Pacht, JD
Facts
The Internal Revenue Service (IRS) assessed a 100 percent tax penalty against Vosters (plaintiff) after rejecting Vosters’s oral request for an appellant hearing. The IRS rejected Vosters’s request because its published procedures (IRS Revenue Procedure 61-27) provided that Vosters had to submit a written protest letter to obtain an appellant hearing. Vosters sued the United States (defendant), seeking to invalidate the penalty and arguing that he was denied his right to an appellant hearing because an IRS representative allegedly told him that his oral request for an appellant hearing was sufficient.
Rule of Law
Issue
Holding and Reasoning ()
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