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making frivolous allegations such as that the IRS engaged in an
“egregious” pattern and practice of issuing excessive and
wrongful assessments.
For the foregoing reasons, we shall grant respondent’s
motion for summary judgment. We hold that respondent may proceed
with a levy with respect to petitioner’s 1988, 1989, 1990, 1991,
and 1992 tax years.
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011