T.C. Memo. 2003-115
UNITED STATES TAX COURT
CARTER B. TATUM, JR. AND BARBARA B. TATUM, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1126-01L. Filed April 22, 2003.
David L. Miller, for petitioners.
Nina P. Ching, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: This case arises from petitioners’ request
for our review (pursuant to section 63301) of respondent’s decision
to proceed with collection by levy with respect to their
outstanding 1990 and 1991 tax liabilities. The issue to be
1 All section references are to the Internal Revenue Code
in effect for the years in issue.
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