Richard S. Cotler - Page 1
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.
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Last modified: November 10, 2007