T.C. Memo. 2002-14
UNITED STATES TAX COURT
SIMONE JOYE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10338-00L. Filed January 14, 2002.
Simone Joye, pro se.
Gerard Mackey, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, 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 determina-
tion).
The issues remaining for decision are:
(1) Did respondent correctly determine in the notice of
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