Noel Nelson, president of the Maryland Patriots, beat the IRS a second time in tax court in his CDPH case. Noel was aided and assisted by famed litigator Dr. Robert Clarkson.
On Feb 12, 2008 District Counsel for the IRS filed a motion for summary judgment to throw this brave patriot out of court. On March 13, this brave patriot stalwart filed his Opposition to Motion for Summary Judgment written by extraordinary brief writer Dr. Clarkson, with the competent clerical assistance of the Executive PN Secretary.
On May 5, the tax court judge denied the motion for summary judgment by the top IRS attorney. This is a solid victory because the tax court almost always grants such requests from the powerful law firm of the evil tax collectors.
This is a collection due process hearing (CDPH) case from eight years ago. Noel beat them in November 2005 before the Chief Judge of the Tax Court. This steadfast patriot requested a collection hearing as provided under IRC 6330. The appeals division of the IRS denied Noel his rights. Noel did not quit—he kept fighting. Therefore he won.
He was able to file all his papers timely and correctly because the able and efficient PN Secretary was on top of this case.
Copies of Noel’s pleadings in both cases are on the CDPH section of the PN website. Click here to view them. Also the tax court docket is available on the tax court website.