T.C. Memo. 2002-210
UNITED STATES TAX COURT
W. RICHARD MORGAN AND JANICE J. MORGAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10641-00L. Filed August 20, 2002.
Lori J. Sellers and Michael C. Phillips, for petitioners.
Michael L. Boman, for respondent.
MEMORANDUM OPINION
COHEN, Judge: The within proceeding was commenced in
response to a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330. We must decide whether
respondent should be permitted to levy on petitioners’ assets to
collect a tax liability owed by petitioners for 1983. Unless
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