T.C. Memo. 2003-206
UNITED STATES TAX COURT
JOHN R. PEACOCK, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6168-02L. Filed July 15, 2003.
Noel W. Spaid, for petitioner.
Karen N. Sommers, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: The issue for decision is whether respondent
may proceed with his proposed collection activity relating to
petitioner’s 1994 tax liability.
FINDINGS OF FACT
Petitioner failed to file his 1994 Federal income tax
return. On April 18, 1997, respondent sent petitioner a notice
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