T.C. Memo. 2007-283 UNITED STATES TAX COURT RICHARD S. COTLER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11565-05L. Filed September 19, 2007. Charles L. Ruffner, for petitioner. Derek P. Richman, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION VASQUEZ, Judge: Pursuant to section 6330(d),1 petitioner, Richard S. Cotler (Mr. Cotler), seeks review of respondent’s determination to proceed with collection of his 1997 and 1998 tax liabilities. The issue for decision is whether the disability 1 Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007