T.C. Memo. 2007-261 UNITED STATES TAX COURT MITRA H. SALMASSI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20091-05L. Filed August 30, 2007. Mitra H. Salmassi, pro se. Kaelyn J. Romey, for respondent. MEMORANDUM OPINION HALPERN, Judge: This case is before the Court to review a determination (the determination) by respondent’s Appeals Office (Appeals) to proceed with the collection of petitioner’s Federal income tax liabilities for 2000, 2001, and 2002. We review the determination pursuant to sections 6320(c) and 6330(d)(1).1 1 While petitioner checked the box on the petition indicating that the petition was for redetermination of a deficiency, clearly this action concerns a collection action, and (continued...)Page: 1 2 3 4 5 NextLast modified: November 10, 2007