T.C. Memo. 2004-6
UNITED STATES TAX COURT
MICHAEL CIPOLLA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7131-02L. Filed January 5, 2004.
Michael Cipolla, pro se.
Theresa G. McQueeney, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: Pursuant to section 6330(d), petitioner
seeks review of respondent’s determination to proceed with
collection of his 1997 income tax.1 On December 2, 2002,
respondent orally moved to have the Court impose against
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended.
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