Brown v. Commissioner

ORDER

James E. Brown appeals pro se from a decision of the tax court that dismissed a “Petition for Lien or Levy Action,” which he had filed under 26 U.S.C. § 6330(d)(1)(A). His appeal has been referred to a panel of this court pursuant to Rule 34(j)(l), Rules of the Sixth Circuit. Upon review, we unanimously agree that oral argument is not needed in this case. Fed. R.App. P. 34(a).

The Internal Revenue Service (“IRS”) notified Brown of a deficiency in 1995, alleging that he had not reported an award of back pay as taxable income. Brown filed a petition in the tax court contesting his tax…