United States Tax Court
Filed: Aug. 26, 2013
T.C. Memo. 2013-194 UNITED STATES TAX COURT STEPHEN R. BLACKMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 22890-09L. Filed August 26, 2013. Ronny Buni, for petitioner. Mimi M. Wong and Michael J. De Matos, for respondent. MEMORANDUM OPINION FOLEY, Judge: The issue for decision is whether respondent abused his discretion in sustaining a notice of Federal tax lien (NFTL) relating to petitioner’s -2- [*2] 2007 tax liability. The parties submitted this case fully stipul..