T.C. Memo. 2003-230 UNITED STATES TAX COURT CHARLES BRODMAN AND TERESA BRODMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16598-02L. Filed August 1, 2003. Jerry Arthur Jewett, for petitioners. Michelle M. Lippert, for respondent. MEMORANDUM OPINION COHEN, Judge: The petition in this case was filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. The issues for decision are whether there was an abuse of discretion in a determination that collection action could proceed and whether the Court should impose a penalty under section 6673. UnlessPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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