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 ofPage: 1 2 3 4 5 6 7 8 Next
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