United States Tax Court June 25, 2020, 6188-19P (Vivian Ruesch v. Commissioner)

154 T.C. No. 13

UNITED STATES TAX COURT

VIVIAN RUESCH, Petitioner v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 6188-19P. Filed June 25, 2020.

P failed to pay assessed penalties under I.R.C. sec. 6038 total-

ing $160,000. R certified P’s liability for those penalties to the Secre-

tary of State as a “seriously delinquent tax debt” within the meaning

of I.R.C. sec. 7345(b).