T.C. Memo. 2004-178
UNITED STATES TAX COURT
JOSEPH W. MCBRIDE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15990-03L. Filed August 2, 2004.
Joseph W. McBride, pro se.
Pamela Karr Harrison, for respondent.
MEMORANDUM OPINION
WHALEN, Judge: This is a levy action commenced by
petitioner under section 6330(d) of the Internal Revenue
Code and Rule 331 of the Tax Court Rules of Practice and
Procedure. Hereinafter, all section references are to the
Internal Revenue Code, and all Rule references are to the
Tax Court Rules of Practice and Procedure. Petitioner
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