T.C. Memo. 2002-307
UNITED STATES TAX COURT
CAROL A. BLACK AND WILLIAM R. ADAMS, JR., Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6443-01L. Filed December 17, 2002.
Carol A. Black and William R. Adams, Jr., pro sese.
Jack T. Anagnostis, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, 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. The issues for
decision are whether the Appeals officer conducting the hearing
abused his discretion in refusing to accept petitioners’ proposal
for an installment agreement and whether petitioners are liable
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