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WADLEIGH v. COMMISSIONER

Docket No. 10783-07L.

134 T.C. 280 (2010)

VANCE L. WADLEIGH, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed June 15, 2010.

Attorney(s) appearing for the Case

John A. Strain, for petitioner.

Spencer T. Stowe, for respondent.

OPINION

MARVEL, Judge:

Pursuant to section 6330(d),1 petitioner seeks review of respondent's determination to sustain a proposed levy on petitioner's interest in his pension. The levy relates to petitioner's unpaid 2001 Federal income tax liability. The issue for decision is whether respondent abused his discretion when he sustained the proposed levy. To resolve this issue, we must first decide whether a section 6321 lien...

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