ROSENBLOOM v. COMMISSIONER OF INTERNAL REVENUE

No. 8055-05L.

T.C. Memo. 2011-140

MARK L. ROSENBLOOM, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed June 21, 2011.


Attorney(s) appearing for the Case

Jonathan P. Decatorsmith 1 and Alan F. Segal , for petitioner.

Mark J. Miller and James E. Schacht , for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

HOLMES, Judge.

In the summer of 1997 an IRS agent visited the office of a down-on-his-luck Chicago lawyer named Mark Rosenbloom. Rosenbloom knew he owed back taxes—he had signed installment agreements with the IRS in 1988 and 1993. But his severe personal problems had caused him to delay sending in updated financial information and to miss a couple months' payments. The agent squeezed hard, threatening to shut...

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