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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