Sean McNamee v. Commissioner

T.C. Memo. 2020-37

UNITED STATES TAX COURT SEAN MCNAMEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2458-19L. Filed March 18, 2020. Robert S. Fink and Usman Mohammad, for petitioner. Marissa J. Savit and Mimi M. Wong, for respondent. MEMORANDUM OPINION LAUBER, Judge: In this collection due process (CDP) case petitioner seeks review pursuant to section 6330(d)(1)1 of a determination by the Internal Revenue 1 All statutory references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice and…