Edward P. Heaphy - Page 1

                                 T.C. Memo. 2004-48                                   

                               UNITED STATES TAX COURT                                

                           EDWARD P. HEAPHY, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6799-02L.            Filed March 5, 2004.                   

               Edward P. Heaphy, pro se.                                              
               Monica J. Miller, for respondent.                                      

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               JACOBS, Judge:  This case arises from petitioner’s request             
          for our review of respondent’s determination that respondent’s              
          filing of a Federal tax lien with respect to the collection of              
          petitioner’s unpaid tax liability for 1997 was appropriate.  The            
          issue to be resolved is whether respondent abused his discretion            
          in making that determination.  In his trial memorandum,                     

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