Brown v. Comm'r

GREGORY R. BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Brown v. Comm'r

No. 8368-02L

United States Tax Court

T.C. Memo 2003-261; 2003 Tax Ct. Memo LEXIS 261; 86 T.C.M. (CCH) 347;

September 9, 2003, Filed

Decision for Commissioner.

Jerry Arthur Jewett, for petitioner.

Michelle M. Lippert, for respondent.

Haines, Harry A.

Haines

MEMORANDUM OPINION

HAINES, Judge: The petition in this case was filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. The issues for decision are whether respondent abused his discretion in determining…