T.C. Memo. 2002-209
UNITED STATES TAX COURT
MICHAEL T. & LEONE CAREY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9014-01L. Filed August 20, 2002.
Michael T. Carey, pro se.
Jeremy L. McPherson, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioners petitioned the Court under section
6330(d) to review respondent’s determination as to a proposed
levy. Respondent proposed the levy to collect Federal income tax
(including an accuracy-related penalty and interest) that he
determined petitioners owe for 1996. Respondent issued a
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