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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