Henry Hermanus Van Es v. Commissioner

115 T.C. No. 25

UNITED STATES TAX COURT HENRY HERMANUS VAN ES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1134-00L. Filed October 13, 2000. With regard to P’s 1994 tax year, R assessed a tax deficiency (along with penalties and interest) and three sec. 6702, I.R.C., frivolous return penalties (along with related interest), of which R collected a portion. As to the uncollected portion of those amounts, R issued a levy notice. Pursuant to sec. 6330(b), I.R.C., P requested an Appeals hearing from R’s Appeals Office. After review, an Appeals officer issued to P a notice…