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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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