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. After
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