T.C. Memo. 2004-30
UNITED STATES TAX COURT
STEPHEN MITCHELL DAY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1867-03L. Filed February 5, 2004.
Stephen Mitchell Day, pro se.
William J. Gregg, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This case was
commenced in response to a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 63301 (notice of
determination). The issue for decision is whether respondent
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
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