T.C. Memo. 2003-172
UNITED STATES TAX COURT
JOHN JOSEPH WINGERT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9433-01L. Filed June 11, 2003.
John Joseph Wingert, pro se.
Ann M. Welhaf and Jeffrey E. Gold, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent sent petitioner a Notice of
Determination Concerning Collection Action(s) Under Sections 6320
and/or 6330 (the lien or levy determination) on July 13, 2001, in
which respondent determined to proceed with collection from
petitioner of his tax liabilities for 1994, 1995, and 1996 (1994-
96). The issue for decision is whether respondent’s
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