T.C. Memo. 2001-213
UNITED STATES TAX COURT
ROY WATSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3609-00L. Filed August 10, 2001.
Roy Watson, pro se.
Pamela J. Sewell, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: This case is based on a petition filed
under section 6330(d) for review of a determination made by
respondent’s Office of Appeals (Appeals) that respondent’s action
to collect certain taxes may proceed. By Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330,
dated February 24, 2000 (the notice), Appeals determined that
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