MURPHY v. COMMISSIONER OF INTERNAL REVENUE

No. 06-1109.

469 F.3d 27 (2006)

Edward F. MURPHY, Petitioner, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee.

United States Court of Appeals, First Circuit.

Decided November 20, 2006.


Attorney(s) appearing for the Case

Timothy J. Burke for appellant.

Rachel I. Wollitzer, Attorney, Tax Division, Department of Justice, with whom Eileen J. O'Connor, Assistant Attorney General and Jonathan S. Cohen, Attorney, Tax Division, Department of Justice, were on brief, for appellee.

Before SELYA and HOWARD, Circuit Judges, and SMITH, District Judge.


HOWARD, Circuit Judge.

Edward F. Murphy owed federal income taxes in excess of $250,000 for 1992-2001. He offered to settle this liability by paying $10,000. The Internal Revenue Service (IRS) rejected Murphy's offer, concluding that he could afford a larger settlement payment. Murphy appealed to the United States Tax Court, which upheld the IRS's ruling. Murphy now appeals the Tax Court's decision. We affirm.

I.

In April 2002, the IRS issued Murphy...

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