Williams v. Comm'r
United States Tax Court
P filed a petition for judicial review pursuant to sec. 6330, I.R.C., in response to a determination by R that levy action was appropriate. Held: Because P has advanced groundless complaints in dispute of the notice of intent to levy, R's determination to proceed with collection action is sustained. Held, further, a penalty under sec. 6673, I.R.C., is due from P and is awarded to the United States in the amount of $ 5,000.
1Opinion of the Court
JAMES VERNON WILLIAMS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Williams v. Comm'r
No. 13821-03L
United States Tax Court
T.C. Memo 2005-94; 2005 Tax Ct. Memo LEXIS 94;
May 2, 2005, Filed
P filed a petition for judicial review pursuant to sec.
6330, I.R.C., in response to a determination by R that levy
action was appropriate.
Held: Because P has advanced groundless complaints
in dispute of the notice of intent to levy, R's determination to
proceed with collection action is sustained.
Held, further, a penalty under sec. 6673,
I.R.C., is due from P and is awarded to the United States in the
a…
2Cases cited16 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Woodral v. CommissionerUnited States Tax Court · 1999
- Glenn Crain v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1984
- Davis v. CommissionerUnited States Tax Court · 2000
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3Cited by6 opinions
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- Michael A. Zapara and Gina A. Zapara v. CommissionerUnited States Tax Court · 2006
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