Vinatieri v. Comr., 133 T.C. 392 (2009)

(IRS held to have abused its discretion when it proceeded with levy to collect taxpayer's unpaid tax; taxpayer established that levy would create economic hardship - taxpayer couldn't find employment due to terminal illness; while taxpayer not current in filing tax returns, Tax Court could not find any cases in which requirement that taxpayer be current with filing returns be applied to taxpayers that meet economic hardship criteria).