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.Page: 1 2 3 4 5 6 7 8 9 10 Next
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