Terry Hiram Pierson v. Commissioner of Internal Revenue

Summary

The Court dismissed the taxpayer’s petition because he had received a notice of deficiency and therefore could not challenge the existence or amount of that liability in a later collection-review proceeding. He also failed to identify any challenge to the proposed levy or any alternative collection method, leaving no justiciable issue for review. The Court declined to impose a penalty but warned that frivolous or delay-motivated lien or levy actions may result in a penalty under section 6673(a)(1).