T.C. Memo. 2003-345
UNITED STATES TAX COURT
LOUIS FUSARO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13282-01L. Filed December 29, 2003.
Willard D. Horwich, for petitioner.
Irene S. Carroll, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: The petition in this case was filed in
response to a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 (notice of
determination). The issue for decision is whether respondent
may levy on petitioner’s pension to collect a tax liability owed
by petitioner for 1990 through 1994.
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