Coastal Luxury Management Inc. v. Commissioner

T.C. Memo. 2019-43

UNITED STATES TAX COURT COASTAL LUXURY MANAGEMENT INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 24206-16L. Filed April 29, 2019. Timothy S. Vick and Jeannette K. Witten, for petitioner. Jeffery D. Rice and Janice B. Geier, for respondent. MEMORANDUM OPINION VASQUEZ, Judge: In this collection due process (CDP) case, petitioner seeks review pursuant to section 6330(d)(1)1 of the determination by the Internal 1 All section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court Rules…