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Held, further, R may proceed with collection of
balances due as determined in a Notice Of Determination
Concerning Collection Action(s) Under Section 6320
and/or 6330.
Robert Holliday, pro se.
Jonae A. Harrison, for respondent.
MEMORANDUM OPINION
NIMS, Judge: This case arises from a petition for judicial
review filed in response to a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330. Unless
otherwise indicated, all section references are to sections of
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. This case was submitted fully stipulated pursuant to
Rule 122, and the facts are so found. The stipulation of the
parties with accompanying exhibits is incorporated herein by this
reference.
Background
At the time the petition was filed in this case, petitioner
resided in Phoenix, Arizona.
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