T.C. Memo. 2004-231
UNITED STATES TAX COURT
KATHRYN ANN PICCHIOTTINO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 784-04L. Filed October 12, 2004.
P filed a petition for judicial review pursuant to
sec. 6330, I.R.C., in response to a determination by R
that levy action was appropriate.
Held: Because the record shows that no period of
limitations precludes collection and because P failed
to submit any current financial documentation in
support of her claims of inability to pay, R’s
determination to proceed with collection action is
sustained.
Kathryn Ann Picchiottino, pro se.
Jonae A. Harrison, for respondent.
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