Will K. Ng - Page 1

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                              T.C. Memo. 2007-8                                       


                               UNITED STATES TAX COURT                                


                              WILL K. NG, Petitioner v.                               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 3883-05L.          Filed January 16, 2007.                  


               John Gigounas, for petitioner.                                         
               Andrew R. Moore, for respondent.                                       


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               VASQUEZ, Judge:  Pursuant to section 6330(d),1 petitioner              
          seeks review of respondent’s determination regarding collection             
          of his 1993, 1994, and 1995 income tax liabilities.  The issue              


               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code, and all Rule references are to the Tax           
          Court Rules of Practice and Procedure.