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CREWS v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 18940-16L.

T.C. Memo. 2019-80

KELVIN R. CREWS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

United States Tax Court.

Filed June 27, 2019.

Attorney(s) appearing for the Case

Keith Howard Johnson , Adam L. Heiden , and Michael P. Tyson , for petitioner.

Randall B. Childs and A. Gary Begun , for respondent.

MEMORANDUM OPINION

This is a collection-due-process ("CDP") appeal pursuant to section 6330(d)(1),1 in which petitioner, Kelvin R. Crews, asks us to review the July 28, 2016 determination by the IRS Office of Appeals to sustain a proposed levy to collect section 6672 trust-fund-recovery penalties...

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