LEGGETT v. COMMISSIONER

Docket No. 15167-04L.

92 T.C.M. 551 (2006)

T.C. Memo. 2006-277

William M. Leggett v. Commissioner.

United States Tax Court.

December 28, 2006.


Attorney(s) appearing for the Case

William M. Leggett, pro se.

Monica J. Miller, for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge:

This case is before the Court on a petition for judicial review of a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. The issues for decision are: (1) Whether respondent may proceed with collection by levy of petitioner's tax liabilities for the 1994, 1995, and 1996 taxable years; and (2) whether the Court should impose a penalty pursuant to section 6673(a).

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