Thomas G Collier - Page 1

                                 T.C. Memo. 2004-171                                  

                               UNITED STATES TAX COURT                                

                          THOMAS G. COLLIER, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2538-03L.            Filed July 21, 2004.                   

                    P filed a petition for judicial review pursuant to                
               sec. 6330, I.R.C., in response to a determination by R                 
               that levy action is appropriate.                                       
                    Held:  Because there was no abuse of discretion by                
               R in concluding that P’s noncompliance with Federal tax                
               filing obligations would render him ineligible for                     
               collection alternatives, R’s determination to proceed                  
               with collection action is sustained.                                   

               Thomas G. Collier, pro se.                                             
               James M. Payton, for respondent.                                       

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