Randal W. Howard - Page 1

                                 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                 
                    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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