Herbert and Rosalie Clark v. Commissioner

125 T.C. No. 7

UNITED STATES TAX COURT HERBERT AND ROSALIE CLARK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3082-05L. Filed September 26, 2005. R issued a notice of levy on Ps’ State tax refund to collect unpaid assessed additions to tax. After Ps requested a hearing under sec. 6330, I.R.C., on the appropriateness of the levy, R determined that the levy was appropriate. Held: The Court has jurisdiction under sec. 6330(d), I.R.C., to review R’s determination regarding the levy upon Ps’ State tax refund. Jeffrey E. Rattner and Steve Mather, for petitioners. Elaine T.…