T.C. Memo. 2004-106
UNITED STATES TAX COURT
JERRY B. AND DONNA E. CLAWSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18716-02L. Filed April 23, 2004.
Mitchell I. Horowitz, for petitioners.
Michael Pesavento, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: This proceeding was commenced in response to
a Notice of Determination Concerning Collection Action Under
Section 6330 (notice of determination). The notice of
determination sustained a proposed levy with respect to
petitioners’ unpaid income tax liabilities for 1999 and 2000.
The issue for decision is whether the Appeals officer abused his
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Last modified: May 25, 2011