T.C. Memo. 2004-171
UNITED STATES TAX COURT
THOMAS G. COLLIER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2538-03L. Filed July 21, 2004.
P filed a petition for judicial review pursuant to
sec. 6330, I.R.C., in response to a determination by R
that levy action is appropriate.
Held: Because there was no abuse of discretion by
R in concluding that P’s noncompliance with Federal tax
filing obligations would render him ineligible for
collection alternatives, R’s determination to proceed
with collection action is sustained.
Thomas G. Collier, pro se.
James M. Payton, for respondent.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011