Orian v. Comm'r
United States Tax Court
Ps filed petitions for judicial review pursuant to sec. 6320 and/or 6330, I.R.C., in response to determinations by R that lien and levy action was appropriate. Held: R's filing of the lien and levy to protect the Government's interest does not constitute an abuse of discretion. R's determination to proceed with collection action is sustained.
1Opinion of the Court
MORDECHAI ORIAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent;
GLOBAL HORIZONS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Orian v. Comm'r
Docket Nos. 26466-07L, 10791-08L
United States Tax Court
T.C. Memo 2010-234; 2010 Tax Ct. Memo LEXIS 269; 100 T.C.M. (CCH) 356;
October 25, 2010, Filed
Appropriate orders and decisions will be entered.
Ps filed petitions for judicial review pursuant to sec. 6320 and/or 6330, I.R.C., in response to determinations by R that lien and levy action was appropriate.
Held: R's filing of the lien and levy to protect the Government's…
2Cases cited24 opinions
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