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RAZO v. COMMISSIONER

Dkt. No. 16969-02L.

87 T.C.M. 1234 (2004)

T.C. Memo. 2004-101

Segudino and Delfa Razo v. Commissioner.

United States Tax Court.

Filed April 9, 2004.

Attorney(s) appearing for the Case

David P. Leeper, for petitioners.

Michael W. Bentley and Gordon P. Sanz, for respondents.

MEMORANDUM OPINION

GOEKE, Judge:

This proceeding was commenced in response to a "NOTICE OF DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER SECTION 6320 AND/OR 6330" (notice of determination). The notice of determination sustained the Federal tax lien, but suspended petitioners' account as "temporarily not collectible". The issue for decision is whether it was an abuse of discretion for respondent's Appeals officer to sustain the lien and reject petitioners...

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