T.C. Memo. 2007-31
UNITED STATES TAX COURT
JOHN ALFRED LASZLOFFY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12601-05L. Filed February 7, 2007.
John Alfred Laszloffy, pro se.
Karen Nicholson Sommers, for respondent.
MEMORANDUM OPINION
SWIFT, Judge: This matter is before us under Rule 121 on
the parties’ cross-motions for summary judgment. The underlying
issue in this collection case is whether respondent’s Appeals
Office abused its discretion in sustaining respondent’s proposed
levy action against petitioner’s property.
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