T.C. Memo. 2004-218
UNITED STATES TAX COURT
JOSEPH A. AND CAROL DELVECCHIO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6893-03L. Filed September 27, 2004.
Joseph A. DelVecchio and Carol DelVecchio, pro sese.
Leonard T. Provenzale, for respondent.
MEMORANDUM OPINION
LARO, Judge: Petitioners, while residing in Stuart,
Florida, petitioned the Court under section 6330(d) to review
respondent’s determination as to his proposed levy upon
petitioners’ property.1 Respondent proposed the levy to collect
1 Unless otherwise noted, section references are to the
applicable versions of the Internal Revenue Code. Rule
references are to the Tax Court Rules of Practice and Procedure.
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