T.C. Memo. 2003-183
UNITED STATES TAX COURT
DOROTHY MOORHOUS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10761-00L. Filed June 24, 2003.
John Franklin Rodgers, for petitioner.
Jeffery E. Gold, for respondent.
MEMORANDUM OPINION
COLVIN, Judge: On October 6, 2000, respondent sent
petitioner a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 (the lien or levy
determination), in which respondent determined that collection
from petitioner of her unpaid tax, additions to tax, and interest
for 1989-92 would proceed.
The sole issue for decision is whether respondent’s refusal
to consider petitioner’s offer in compromise because petitioner
Page: 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011