T.C. Memo. 2005-100
UNITED STATES TAX COURT
RANDAL W. HOWARD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8719-03L. Filed May 9, 2005.
P filed a petition for judicial review pursuant to
sec. 6330, I.R.C., in response to a determination by R
that levy action was appropriate.
Held: Because P has advanced groundless
complaints in dispute of the notice of intent to levy,
R’s determination to proceed with collection action is
sustained.
Held, further, because the underlying tax
liability is not at issue and R has shown good cause,
suspension on levy action is lifted pursuant to sec.
6330(e)(2), I.R.C.
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 $10,000.
Randal W. Howard, pro se.
Cameron M. McKesson and Robin M. Ferguson, for respondent.
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