T.C. Memo. 2004-224
UNITED STATES TAX COURT
LARRY R. JOHNSTON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5380-04L. Filed October 5, 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.
Held: Because P has advanced solely groundless
complaints in dispute of the notice of lien, R’s
determination to proceed with collection action is
sustained.
Held, further, damages under sec. 6673, I.R.C.,
are due from P and are awarded to the United States in
the amount of $3,000.
Larry R. Johnston, pro se.
Jonae A. Harrison, for respondent.
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