SCHNELLER v. COMMISSIONER

Dkt. No. 14477-05L.

91 T.C.M. 1169 (2006)

T.C. Memo. 2006-99

Charles A. Schneller v. Commissioner.

United States Tax Court.

May 11, 2006.


Attorney(s) appearing for the Case

Charles A. Schneller, pro se;

John W. Sheffield, for respondent.


MEMORANDUM OPINION

GOEKE, Judge:

The petition in this case was filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination).1 At issue is (1) whether respondent abused his discretion in allowing the collection action to proceed, and (2) whether frivolous arguments advanced by petitioner warrant the imposition by the Court of a section 6673(a) penalty....

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