Thomas C. Johnson - Page 1

                                 T.C. Memo. 2004-73                                   


                               UNITED STATES TAX COURT                                


                          THOMAS C. JOHNSON, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 3028-02L.            Filed March 18, 2004.                  

                    P filed a petition for judicial review pursuant to                
               secs. 6320 and 6330, I.R.C., in response to a                          
               determination by R to leave in place a filed notice of                 
               Federal tax lien for the 1995, 1996, and 1999 years.                   
                    Held:  Because (1) P is not entitled to dispute                   
               his underlying tax liabilities for 1995 and 1996, (2) P                
               does not dispute his underlying liability for 1999, and                
               (3) the record does not establish any abuse of                         
               discretion by R, R’s determination to proceed with                     
               collection action is sustained.                                        

               Thomas C. Johnson, pro se.                                             
               Horace Crump, for respondent.                                          









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