T.C. Memo. 2003-302 UNITED STATES TAX COURT DONALD G. AND CLAUDIA A. WILLIS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6456-02L. Filed November 3, 2003 Mark H. Westlake, for petitioners. Caroline Krivacka, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION SWIFT, Judge: This case arises from a petition for judicial review timely filed in response to a notice of determination concerning collection action under section 6330.1 The notice of 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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