T.C. Memo. 2002-141 UNITED STATES TAX COURT DANIEL J. AND RUTH E. TAPIO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10741-01L. Filed June 4, 2002. Daniel J. Tapio and Ruth E. Tapio, pro sese. Randall L. Preheim, for respondent. MEMORANDUM OPINION GERBER, Judge: This case involves the question of whether respondent, under the provisions of I.R.C. section 6330,1 may proceed with the collection of petitioners’ outstanding and unpaid tax liability. On February 5, 2002, respondent moved for 1 All section references are to the Internal Revenue Code in effect for the period during which respondent has pursued collection, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated.Page: 1 2 3 4 5 6 7 Next
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