T.C. Memo. 2003-322
UNITED STATES TAX COURT
RONALD E. BOYER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8241-02L. Filed November 20, 2003.
Ronald E. Boyer, pro se.
Jason W. Anderson, for respondent.
MEMORANDUM OPINION
KROUPA, Judge: Petitioner filed his petition under section
6330(d)1 seeking review of respondent’s determination to proceed
with a proposed levy to collect petitioner’s 1986 and 1987
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at all relevant times, all
Rule references are to the Tax Court Rules of Practice and
Procedure, and all dollar amounts are rounded to the nearest
dollar.
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