T.C. Summary Opinion 2004-48 UNITED STATES TAX COURT CAROLYN D. RAMIREZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14154-02S. Filed April 12, 2004. Carolyn D. Ramirez, pro se. Trent D. Usitalo, for respondent. WOLFE, Special Trial Judge: This case was heard pursuant to the provisions of sections 6330(d) and 7463 of the Internal Revenue Code in effect when the petition was filed. Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect at relevant times. The decision to be entered is not reviewable by any other court, and this opinion should not be cited as authority. The sole issue for decision is whether respondent abused his discretion in failingPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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