Winston O. and Paulet P. Smith - Page 1

                                 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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