T.C. Memo. 2006-143 UNITED STATES TAX COURT KENT E. HOVIND, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11894-05L. Filed July 6, 2006. Peter Gibbons, for petitioner. Karen Nicholson Sommers, for respondent. MEMORANDUM OPINION SWIFT, Judge: This matter is before us under Rule 121 on the parties’ cross-motions for summary judgment. The underlying issue in this so-called collection “due process” case involves the appropriateness of respondent’s proposed levy action against petitioner’s property arising from jeopardy assessments respondent made against petitioner.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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