-7- v. Commissioner, 89 T.C. 287, 291 (1987); Vorwald v. Commissioner, T.C. Memo. 1997-15. Once the Commissioner issues the notice of levy, the Commissioner "steps into the shoes of the taxpayer and acquires 'whatever' rights to the property the taxpayer had." United States v. Bell Credit Union, 860 F.2d 365, 368 (10th Cir. 1988) (quoting United States v. National Bank of Commerce, 472 U.S. 713, 713 (1985)). We sustain respondent's determination that petitioner constructively received, and must include in income, the $26,861 distribution from his IRA in 1995. To reflect concessions and the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011