- 2 - 3. Held, further: R’s determination does not constitute an abuse of discretion and is sustained. Hersy Jones, Jr., for petitioner. Alvin A. Ohm, for respondent. MEMORANDUM OPINION HALPERN, Judge: Pursuant to section 6330(d), petitioner seeks review of respondent’s determination to proceed with collection of income taxes and additions to tax for calendar years 1982, 1987, and 1988 (sometimes, the years in issue). Unless otherwise indicated, all section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. All dollar amounts have been rounded to the nearest dollar. Background This case was submitted for decision without trial, pursuant to Rule 122. Facts stipulated by the parties are so found. The stipulation of facts, with attached exhibits, is included herein by this reference. Petitioner objects to two of the exhibits as being irrelevant. At the time the petition was filed, petitioner resided in Coppell, Texas.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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