T.C. Memo. 2002-185
UNITED STATES TAX COURT
GARY GOUGLER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9049-01L. Filed July 31, 2002.
Gary Gougler, pro se.
Russell K. Stewart, for respondent.
MEMORANDUM OPINION
COHEN, Judge: Respondent sent to petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 with respect to petitioner’s Federal income taxes for
1991 and 1992. Petitioner contends that he did not receive a
refund that was due to him for 1986. Unless otherwise indicated,
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