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CALDERONE v. COMMISSIONER

Docket No. 3563-03L.

88 T.C.M. 378 (2004)

T.C. Memo. 2004-240

Geoffrey K. Calderone, Sr. v. Commissioner.

United States Tax Court.

October 19, 2004.

Attorney(s) appearing for the Case

John T. Mulhall III and Thomas E. Redding, for petitioner.

John T. Lortie and Kenneth A. Hochman, for respondent.

MEMORANDUM OPINION

GERBER, Chief Judge.

Petitioner, pursuant to section 6330(d),1 seeks review of respondent's determination to proceed with collection (by means of levy) of petitioner's unpaid 1995 Federal income tax liability. The issue for our consideration is whether, in the context of a section 6330 proceeding, petitioner is entitled to challenge the underlying tax liability for 1995. The resolution of this issue depends...

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