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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Last modified: May 25, 2011