                                 T.C. Memo. 2006-21                                   


                               UNITED STATES TAX COURT                                


                    WILLIAM REESE, Petitioner v. COMMISSIONER OF                      
                            INTERNAL REVENUE, Respondent                              


               Docket No.  1174-05L.            Filed February 9, 2006.               


               William Reese, pro se.                                                 
               Jeffrey E. Gold, for respondent.                                       


                                 MEMORANDUM OPINION                                   
               NIMS, 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 (notice of                         
          determination), in which respondent determined to proceed with

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