T.C. Memo. 2003-234
UNITED STATES TAX COURT
WILLIAM G. WELLS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 163-01L. Filed August 6, 2003.
William G. Wells, pro se.
Lorraine Y. Wu, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Pursuant to section 6330(d),1 petitioner
seeks review of respondent’s determination to proceed with
collection of his 1991 and 1992 tax liabilities.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
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