DISCLAIMER:  The following unofficial case summaries are prepared by the clerk's office
                        as a courtesy to the reader. They are not part of the opinion of the court.

043600P.pdf   03/08/2006  James Robinette  v.  Comm. IRS
   U.S. Court of Appeals Case No:  04-3600
   Agency   
   [PUBLISHED][Colloton, Author, with Arnold and McMillian, Circuit Judges]
   Civil case - Federal tax law. The Tax Court erred in finding that the
   IRS has abused its discretion in imposing a levy for the amount remaining
   on taxpayer's original compromised liability; the case should be reviewed
   upon the basis of the evidence presented to the appeals officer; the
   appeals officer did not abuse his discretion in declining to excuse
   taxpayer's breach of an express condition of the agreement, nor did he err
   in refusing to reinstate the agreement.