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RAMEY v. COMMISSIONER

Docket No. 6986-19L.

156 T.C. 1 (2021)

156 T.C. No. 1

WILEY RAMEY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 14, 2021.

Attorney(s) appearing for the Case

Wiley Ramey, pro se.

Joanne H. Kim , Justine S. Coleman , and Jordan S. Musen , for respondent.

OPINION

The Internal Revenue Code (the "Code") authorizes the Internal Revenue Service ("IRS") to levy on (that is, to seize) property or property rights of any person who is liable for any tax and has failed to pay that tax after proper notice and demand. Secs. 6331, 7701(a)(11)(B), (12)(A)(i).1

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