Kenneth A. Schrems - Page 1

                                 T.C. Memo. 2003-25                                   

                               UNITED STATES TAX COURT                                

                          KENNETH A. SCHREMS, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10848-01L.              Filed January 28, 2003.             

               Kenneth A. Schrems, pro se.                                            
               Michael A. Pesavento, for respondent.                                  

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               FOLEY, Judge:  The issue for decision is whether respondent            
          abused his discretion in determining to proceed with collection.            
                                  FINDINGS OF FACT                                    
               Petitioner failed to file income tax returns relating to               
          1994, 1995, and 1996.  On December 28, 1998, respondent assessed            
          deficiencies against petitioner relating to those years.  As of             

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