T.C. Memo. 2003-319
UNITED STATES TAX COURT
EDWIN E. AND BERTALINA ALVAREZ, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13286-02L. Filed November 18, 2003.
Edwin E. Alvarez and Bertalina Alvarez, pro sese.
Irene Scott Carroll, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge: The petition in this case was filed under
section 6330(d)1 in response to a Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330
(the notice of determination). The issue for decision is whether
1Unless otherwise indicated, all section references are to
the Internal Revenue Code currently in effect.
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