David Bach, (2008)

Extract

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David Bach, (2008)

T.C. Memo. 2008-202

UNITED STATES TAX COURT DAVID BACH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23061-06L. Filed August 27, 2008.

David Bach, pro se.

Steven M. Webster, for respondent.

MEMORANDUM OPINION WELLS, Judge: Petitioner seeks review, pursuant to section 6330,1 of respondent's determination to proceed with the collection of petitioner's tax liability for the 1993 taxable year. The issue we must decide is whether petitioner is liable -2for the underlying tax liability for taxable year 1993,2 and, therefore, whether respondent may proceed with the collection of that liability.

Background Some of the facts and certain exhibits have been stipulated. The parties' stipulations of fact are incorporated in this opinion by reference and are found as facts in the instant case. At the time he filed his petition, petitioner resided in South Carolina.

Petitioner did not file a return for taxabl...

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