Daniel J. and Ruth E. Tapio - Page 1

                                 T.C. Memo. 2002-141                                  

                               UNITED STATES TAX COURT                                

                     DANIEL J. AND RUTH E. TAPIO, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10741-01L.              Filed June 4, 2002.                 

               Daniel J. Tapio and Ruth E. Tapio, pro sese.                           
               Randall L. Preheim, for respondent.                                    

                                 MEMORANDUM OPINION                                   
               GERBER, Judge:  This case involves the question of whether             
          respondent, under the provisions of I.R.C. section 6330,1 may               
          proceed with the collection of petitioners’ outstanding and                 
          unpaid tax liability.  On February 5, 2002, respondent moved for            

               1 All section references are to the Internal Revenue Code in           
          effect for the period during which respondent has pursued                   
          collection, and all Rule references are to the Tax Court Rules of           
          Practice and Procedure, unless otherwise indicated.                         

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