T.C. Memo. 2006-203 UNITED STATES TAX COURT JERRE MARVINE WOOD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16390-05L. Filed September 25, 2006. Jerre Marvine Wood, pro se. Jeffrey S. Luechtefeld, for respondent. MEMORANDUM OPINION WELLS, Judge: The instant case is before the Court on respondent’s motion for summary judgment pursuant to Rule 121 and to impose a penalty pursuant to section 6673. The issue we must decide is whether respondent’s Appeals Office abused its discretion in determining to proceed with collection of petitioner’s tax liability for taxable year 2002. AfterPage: 1 2 3 4 5 6 7 Next
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