T.C. Memo. 2002-304
UNITED STATES TAX COURT
STUART M. SMITH, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10478-00L. Filed December 12, 2002.
Stuart M. Smith, Jr., pro se.
Alvin A. Ohm, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioner, while residing in Dallas, Texas,
petitioned the Court under section 6330(d) to review respondent’s
determination as to his proposed levy upon petitioner’s property.
Respondent proposed the levy to collect petitioner’s 1985 and
1986 Federal income tax liability (including accuracy-related
penalties and interest). For the reasons set forth below, we
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