Bruce M. Kraft v. Commissioner

142 T.C. No. 14

UNITED STATES TAX COURT BRUCE M. KRAFT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3602-12L. Filed April 23, 2014. P filed a petition for review pursuant to I.R.C. sec. 6330 in response to R’s determination to proceed with collection by means of levy. P sought a collection alternative and requested that R invade Trust (T) in order to satisfy P’s income tax liability. P contends that for R to collect from him personally the levy would have to be continuing for some time, resulting in additional interest and costs. P contends that in order for R to meet…