T.C. Memo. 2004-24
UNITED STATES TAX COURT
VICKI S. PLESS AND COY E. PLESS, JR., Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1917-03L. Filed February 3, 2004.
Vicki S. Pless and Coy E. Pless, Jr., pro se.
James R. Rich, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: This case was commenced in response to a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 and a Notice of Determination Concerning
Your Request for Relief from Joint and Several Liability Under
Section 6015. The issue for decision is whether there was an
abuse of discretion in issuing the notices of determination
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