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.
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