- 2 - is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case. The petition in this case was filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination). Pursuant to section 6330(d), petitioner seeks review of respondent’s proposed levy action with respect to his income tax liability for tax year 1999. The issue for decision is whether respondent’s determination to proceed with the proposed levy action for tax year 1999 was an abuse of discretion. Background At the time petitioner filed the petition, he resided in Houston, Texas. Petitioner filed a Federal income tax return for the tax year 1999 which showed tax of $4,587, a withholding credit of $1,922, and a balance due of $2,665. Respondent assessed the tax shown on petitioner’s 1999 return, plus additions to tax and interest. Thereafter, respondent audited petitioner’s 1999 return, determined a deficiency of $1,170, and issued a notice of deficiency. Petitioner filed a petition with this Court with respect to the 1999 tax year, but the case for that year was never tried because the parties agreed to a stipulated decision, which was entered on February 28, 2003. In the decision document, the parties stipulated that there was a deficiency of $1,170 for 1999. The parties further stipulatedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007