T.C. Memo. 2005-90
UNITED STATES TAX COURT
DAVID A. LEHMANN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3386-04L. Filed April 25, 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, a penalty under sec. 6673, I.R.C.,
is due from P and is awarded to the United States in
the amount of $2,500.
David A. Lehmann, pro se.
Jonae A. Harrison, for respondent.
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