- 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.
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