T.C. Memo. 2002-221
UNITED STATES TAX COURT
MICHAEL J. ROBERTS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9831-00L. Filed September 4, 2002.
P filed a petition for judicial review pursuant to
sec. 6330, I.R.C., in response to a determination by R
to proceed with collection by levy of assessed tax
liabilities for 1989, 1990, and 1991.
Held: Because P received a notice of deficiency
for 1989, 1990, and 1991 and failed to seek
redetermination in this Court, P’s underlying tax
liabilities are not properly at issue in this
collection proceeding.
Held, further, because the record does not
establish any abuse of discretion, R’s determination to
proceed with collection action is sustained.
Michael J. Roberts, pro se.
Karen Nicholson Sommers, for respondent.
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