Lehmann 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 $ 2,500.
1Opinion of the Court
DAVID A. LEHMANN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Lehmann v. Comm'r
No. 3386-04L
United States Tax Court
T.C. Memo 2005-90; 2005 Tax Ct. Memo LEXIS 89; 89 T.C.M. (CCH) 1084;
April 25, 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…
2Cases cited15 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Woodral v. CommissionerUnited States Tax Court · 1999
- Davis v. CommissionerUnited States Tax Court · 2000
- Lunsford v. Comm'rUnited States Tax Court · 2001
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