T.C. Memo. 2004-104
UNITED STATES TAX COURT
JUNE H. GINALSKI, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12522-03L. Filed April 22, 2004.
June H. Ginalski, pro se.
Rachael J. Zepeda, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: This matter arises, under section 6320,1 out
of respondent’s filing of a Notice of Federal Tax Lien with
respect to petitioner’s 1993 and 1994 income tax liabilities.
The sole issue presented for our consideration is whether
1 Section references are to the Internal Revenue Code in
effect for the periods under consideration.
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