T.C. Memo. 2006-127
UNITED STATES TAX COURT
JOHN P. AND SHARON LYNN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5948-05L. Filed June 19, 2006.
John P. and Sharon Lynn, pro se.
Timothy B. Heavner, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge: Pursuant to section 6330(d), petitioners seek
judicial review of respondent’s determination to proceed with a
proposed levy concerning petitioners’ 1994 Federal income tax
liability. The issue to be decided is whether respondent’s
determination was an abuse of discretion. All section references
are to the Internal Revenue Code, as amended.
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