T.C. Memo. 2002-129
UNITED STATES TAX COURT
ALAN M. AND MARCIA F. SCHULMAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9567-01L. Filed May 29, 2002.
Alan M. and Marcia F. Schulman, pro sese.
James E. Schacht, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: Petitioners were issued a notice of
determination pursuant to section 6330(c)(3),1 in which it was
determined that a proposed levy should proceed for petitioners’
unpaid tax liabilities. Petitioners filed a petition for
1Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended.
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