T.C. Memo. 2001-181
UNITED STATES TAX COURT
SERVICE ENGINEERING TRUST, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
CHARLES W. AND LORAINE LEDFORD, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 2021-00L, 2658-00L. Filed July 20, 2001.
Joyce Griggs, for petitioners.
Ross M. Greenberg, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: The issue in this case is whether respondent
has met the requirements of section 6320. All section references
are to the Internal Revenue Code as amended.
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