T.C. Memo. 2004-48
UNITED STATES TAX COURT
EDWARD P. HEAPHY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6799-02L. Filed March 5, 2004.
Edward P. Heaphy, 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 respondent’s
filing of a Federal tax lien with respect to the collection of
petitioner’s unpaid tax liability for 1997 was appropriate. The
issue to be resolved is whether respondent abused his discretion
in making that determination. In his trial memorandum,
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