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DAVIS v. COMMISSIONER

Docket No. 13532-99L.

115 T.C. 35 (2000)

RONALD A. DAVIS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 31, 2000.

Attorney(s) appearing for the Case

Thomas W. Roberts, for petitioner.

J. Michael Melvin and Robert A. Varra, for respondent.

OPINION

RUWE, Judge:

This case is based on a petition filed under section 6330(d).1 Respondent has moved for judgment on the pleadings. For convenience, we will combine the facts, which are not in dispute, with our opinion.

Section 6331(a) provides that, if any person liable to pay any tax neglects or refuses to pay such tax within 10 days after notice and demand for payment, the Secretary is authorized to collect...

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