T.C. Memo. 2002-48 UNITED STATES TAX COURT TERRY K. MANN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6263-00L. Filed February 21, 2002. Joyce Griggs, for petitioner. Ross M. Greenberg, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: Petitioner petitioned the Court under section 6330(d).1 We must decide whether (1) respondent abused his discretion under section 6330 and (2) petitioner is liable for a section 6673(a)(1) penalty. 1 Section references are to the Internal Revenue Code applicable to the years in issue.Page: 1 2 3 4 5 6 Next
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