T.C. Memo. 2003-205
UNITED STATES TAX COURT
WINSTON O. AND PAULET P. SMITH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14601-01L. Filed July 15, 2003.
Winston O. and Paulet P. Smith, pro sese.
Lorianne D. Masano, 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
petitioners’ 1982, 1983, 1986, and 1987 tax liabilities.
FINDINGS OF FACT
On December 7, 1998, petitioners and respondent executed an
installment agreement, and petitioners signed Form 900, Tax
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