T.C. Memo. 2004-15
UNITED STATES TAX COURT
ROBERT HAROLD HATHAWAY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 136-02L. Filed January 23, 2004.
Robert Harold Hathaway, pro se.
Monica J. Miller, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: This case arises from petitioner’s request
for our review of respondent’s determination that the filing of a
Federal tax lien with respect to the collection of petitioner’s
unpaid taxes for 1996 and 1997 was appropriate. The issue to be
resolved is whether that determination by respondent constitutes
an abuse of discretion. Respondent raised the issue of whether
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