T.C. Memo. 2002-96
UNITED STATES TAX COURT
KARL PAUL VOSSBRINCK, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 612-01L. Filed April 9, 2002.
Karl Paul Vossbrinck, pro se.
John Aletta, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: On December 14, 2000, respondent issued a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 advising petitioner of respondent’s
intention to proceed with a proposed levy to collect petitioner’s
outstanding income tax liabilities for 1991, 1992, 1993, and
1994. A petition was filed on January 12, 2001, in which
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