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, TaxPage: 1 2 3 4 5 6 7 Next
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