On June 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Nimmo v. Commissioner (T.C. Memo. 2020-72). The sole issue before the court in Nimmo v. Commissioner was whether the IRS abused its discretion in sustaining the collection action against petitioner, who failed to attend (call into) his initial CDP hearing, failed to submit required documentation at his subsequent CDP hearing (on another tax period), and otherwise failed to communicate with