T.C. Memo. 2004-226
UNITED STATES TAX COURT
LEONARD O. PARKER, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4053-03L. Filed October 6, 2004.
Leonard O. Parker, Jr., pro se.
Hieu C. Nguyen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Petitioner lived in New Orleans, Louisiana,
when he filed an offer in compromise relating to his 1992-94 tax
years. Respondent’s Taxpayer Advocate’s Office asked respondent
to place a 45-day hold on collection for those years. On
February 12, 2003, respondent sent petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
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