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Whether it was an abuse of discretion for respondent to decide to
proceed with collection by means of a notice of levy.
Background
Petitioner resided at Middleberg Heights, Ohio, at the time
his petition was filed. Petitioner failed to file 1989, 1990,
and 1991 Federal income tax returns. Petitioner advanced, as the
reason for failing to file, his belief that the Internal Revenue
Service (IRS) would use the information against petitioner in his
litigation with the National Labor Relations Board (NLRB).
Petitioner’s litigation with the NLRB is not related to
petitioner’s section 6330 hearing.
Petitioner is a Vietnam veteran and has been diagnosed by
the Department of Veterans Affairs as “suffering from severe,
chronic Post Traumatic Stress Disorder, a psychiatric condition
which developed as a result of * * * [his] combat experience
during the Vietnam war.” He also suffers from a marked hearing
impairment.
During the early 1990s, petitioner, as the president of
Crystal Window Cleaning Co., was involved in an injunction
proceeding concerning the NLRB’s charges of unfair labor
practices. Injunctions had been granted against petitioner and
his company ordering that certain “anti-union behavior” be
discontinued. Petitioner was found in civil contempt for refusal
to comply with various court orders, and, ultimately, a jury
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