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OZAKI v. COMMISSIONER

Dkt. No. 22808-05L.

93 T.C.M. 912 (2007)

T.C. Memo. 2007-36

Edward Kazuo Ozaki v. Commissioner.

United States Tax Court.

February 20, 2007.

Attorney(s) appearing for the Case

Edward Kazuo Ozaki, for petitioner.

Gregory Stull, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Petitioner petitioned the Court under sections 6320 and 6330(d) to review a determination of the Commissioner's Office of Appeals (Appeals) sustaining respondent's filing of a lien on petitioner's property.1 Respondent filed the lien as to Federal income taxes that respondent considers to be owed by petitioner for 1994 through...

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