Jon David Cooksey - Page 15

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          Conclusion                                                                  
               Except for his claim that he is not liable for the additions           
          to tax under sections 6651(a)(2) and 6654 for 2000, petitioner              
          has raised no other issue with respect to respondent's proposed             
          levy for 2000.  We therefore hold that respondent may proceed               
          with the levy at issue herein.                                              
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          





























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