T.C. Memo. 2005-289
UNITED STATES TAX COURT
HAROLD E. CALL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19609-03L. Filed December 15, 2005.
P filed a petition for judicial review pursuant to
secs. 6320 and 6330, I.R.C., in response to a
determination by R to leave in place a filed notice of
Federal tax lien.
Held: Because P has advanced groundless
complaints in dispute of the filed notice of tax lien,
R’s determination to proceed with collection action is
sustained.
Held, further, a penalty under sec. 6673, I.R.C.,
is due from P and is awarded to the United States in
the amount of $5,000.
Harold E. Call, pro se.
Alan J. Tomsic, for respondent.
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