T.C. Memo. 2006-37
UNITED STATES TAX COURT
ARTHUR A. LEMANN III AND ROBERTA A. LEMANN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12857-02L. Filed March 7, 2006.
Arthur A. Lemann III and Roberta A. Lemann, pro sese.
Susan S. Canavello, for respondent.
MEMORANDUM OPINION
GALE, Judge: The petition in this case was filed in
response to a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330.1 Respondent has moved
1 Unless otherwise noted, all section references are to the
Internal Revenue Code applicable to the periods at issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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