Gillum v. Commissioner

SMITH, Circuit Judge.

Thomas M. Gillum sought judicial review of the Commissioner of Internal Revenue’s notice of determination sustaining a proposed levy to collect Gillum’s delinquent income tax liabilities for 1996-2002 and a tax-lien filing for 1998 and 2000-2002 tax liabilities. Gillum also sought review of the Commissioner’s denial of collection due process (CDP) hearings to his purported nominees and alter egos. Following trial, the tax court1 upheld the Commissioner’s determinations sustaining the filing of the notice of the federal tax lien and proposed levy. Additionally, the tax…