T.C. Memo. 2004-235
UNITED STATES TAX COURT
PHILIP L. AND SARA N. ECKERT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1437-03L. Filed October 13, 2004.
Philip L. and Sara N. Eckert, pro sese.
James A. Kutten, for respondent.
MEMORANDUM OPINION
CARLUZZO, Special Trial Judge: In a Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330
dated January 10, 2003, respondent proposed to proceed with
collection of petitioners’ unpaid 1994 Federal income tax.1
1 Section references are to the Internal Revenue Code in
effect at the time the petition was filed.
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