SWEENEY v. COMMISSIONER

Docket No. 21167-05L.

92 T.C.M. 320 (2006)

T.C. Memo. 2006-213

John N. Sweeney v. Commissioner.

United States Tax Court.

October 3, 2006.


Attorney(s) appearing for the Case

John N. Sweeney, pro se;

Monica J. Miller, for respondent.


MEMORANDUM OPINION

WELLS, Judge:

The instant case is before the Court on respondent's motion for summary judgment pursuant to Rule 1211 and to impose a penalty pursuant to section 6673. The issue we must decide is whether respondent's Appeals Office abused its discretion in determining to proceed with collection of petitioner's tax liability for taxable years 1999, 2001, and 2002. For the reasons stated below, we shall grant...

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