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The sum total of petitioner’s evidence is his testimony at
trial that “Well, my case is simply that I don’t owe the IRS
money.”
The Court finds petitioner’s “evidence” to be insufficient
to cast doubt on either the validity and amount of the underlying
tax liability, or the appropriateness of the collection action.
The Court finds that respondent did not abuse his discretion
in issuing his determination in this case.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011