John P. and Sharon Lynn - Page 1

                                 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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