Coleman Moore v. Commissioner

T.C. Memo. 2019-129

UNITED STATES TAX COURT COLEMAN MOORE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7390-16L. Filed September 30, 2019. Carlos S. Lopez, for petitioner. Adam B. Landy, Nancy M. Gilmore, and Thomas R. Mackinson, for respondent. MEMORANDUM OPINION GOEKE, Judge: Petitioner challenges respondent’s attempt to collect by levy unpaid trust fund recovery penalties (TFRP) for which petitioner is a responsible officer. These matters turn on whether the settlement officer assigned -2- [*2] to petitioner’s hearing under section 63301 abused his discretion by…