T.C. Memo. 2005-290
UNITED STATES TAX COURT
CREVENNE C. AND BARBARA A. CARRILLO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2593-04L. Filed December 20, 2005.
Ps filed a petition for judicial review pursuant
to secs. 6320 and 6330, I.R.C., in response to
determinations by R that lien and levy actions were
appropriate.
Held: Because Ps have advanced groundless
complaints in dispute of the notices of lien and levy,
R’s determination to proceed with collection action is
sustained.
Held, further, a penalty under sec. 6673, I.R.C.,
is due from Ps and is awarded to the United States in
the amount of $5,000.
Crevenne C. and Barbara A. Carrillo, pro sese.
Rollin G. Thorley, for respondent.
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