Daniel A. Colon v. Commissioner

T.C. Memo. 2018-113

UNITED STATES TAX COURT DANIEL A. COLON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13933-16L. Filed July 19, 2018. Nancy Ortmeyer Kuhn, for petitioner. Trevor B. Maddison, for respondent. MEMORANDUM OPINION RUWE, Judge: Pursuant to section 6330(d)(1),1 petitioner seeks review of the Internal Revenue Service Office of Appeals determination to proceed with 1 Unless otherwise indicated, 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 of Practice and…