John A. Roberts - Page 2

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                    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.                                                             







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