T.C. Memo. 2004-208
UNITED STATES TAX COURT
ROBERT NEWSTAT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16989-02L. Filed September 16, 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 is appropriate for the taxable years
1985 and 1999.
Held: With respect to 1985, R’s determination to
proceed with collection action is sustained. With
respect to 1999, the case is remanded for further
consideration by the Internal Revenue Service Office of
Appeals.
Robert Newstat, pro se.
Jack T. Anagnostis, for respondent.
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