CIPOLLA v. COMMISSIONER

Docket No. 7131-02L.

87 T.C.M. 801 (2004)

T.C. Memo. 2004-6

Michael Cipolla v. Commissioner.

United States Tax Court.

Filed January 5, 2004.


Attorney(s) appearing for the Case

Michael Cipolla, pro se.

Theresa G. McQueeney, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

HALPERN, Judge:

Pursuant to section 6330(d), petitioner seeks review of respondent's determination to proceed with collection of his 1997 income tax.1 On December 2, 2002, respondent orally moved to have the Court impose against petitioner a penalty pursuant to section 6673.

FINDINGS OF FACT

Some of the facts have been stipulated and are found accordingly. The stipulation...

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