Leonard Parker - Page 1

                                 T.C. Memo. 2005-294                                  

                               UNITED STATES TAX COURT                                

                            LEONARD PARKER, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2712-00L.            Filed December 22, 2005.               

               Robert E. Kovacevich, for petitioner.                                  
               Catherine L. Campbell, for respondent.                                 

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               COHEN, Judge:  The petition in this case was filed in                  
          response to a Notice of Determination Concerning Collection                 
          Action(s) Under Section 6320 and/or 6330 (notice of                         
          determination).  After concessions by petitioner, the issue for             
          decision is whether there was an abuse of discretion by the                 
          Internal Revenue Service (IRS) in determining that collection of            

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