T.C. Memo. 2004-8
UNITED STATES TAX COURT
JOHNNIE L. TILLMAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11709-02L. Filed January 6, 2004.
Johnnie L. Tillman, pro se.
James A. Kutten, for respondent.
MEMORANDUM OPINION
COHEN, Judge: This proceeding was commenced in response to
a Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330. The issue for decision is whether
there was an abuse of discretion in rejecting petitioner’s offer
to compromise for $100 petitioner’s unpaid Federal income tax
liabilities for 1993, 1994, and 1995 exceeding $13,000 and
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