Hauptman v. Commissioner, No. 15-1071 (8th Cir. 2016)
Annotate this CaseBruce A. Hauptman, an investment consultant, sought judicial review of the Commissioner's notices of determination permitting a levy to collect Hauptman’s unpaid income tax liabilities for tax years 1992 through 1996. The tax court upheld the IRS’s determinations. The court rejected Hauptman’s challenge to the tax court’s jurisdiction where Hauptman cites to no authority to support his claim that there are additional requirements before a tax court can exercise jurisdiction over supplemental notices. The court agreed with the tax court’s conclusion that the Office of Appeals did not abuse its discretion when it rejected Hauptman’s offer-in-compromise based on its well-supported findings that Hauptman had not complied with his income tax obligations, that he had not fully disclosed his financial circumstances during the collection due process proceedings, and that he had not prioritized payment of his tax liabilities. Accordingly, the court affirmed the judgment.
Court Description: Gruender, Author, with Smith, Circuit Judge, and Ketchmark, District Judge] United States Tax Court. There is no support for taxpayer's argument that there are additional requirements before a tax court can exercise jurisdiction over supplemental notices, and his challenge to the tax court's jurisdiction is rejected; the IRS did not err in rejecting tax-payer's offer-in-compromise as the Office Of Appeals' findings that taxpayer had not fully disclosed his financial circumstances during the collection due process proceedings and had not prioritized payment of his tax liabilities were well-supported.
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