T.C. Memo. 2004-86 UNITED STATES TAX COURT THOMAS J. AND BONNIE F. RATKE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9641-01L. Filed March 25, 2004. Jack B. Schiffman, for petitioners. Anne W. Durning, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION FOLEY, Judge: The issue for decision is whether respondent abused his discretion in determining to proceed with collection. FINDINGS OF FACT On April 15, 1994, petitioners timely filed their 1993 Federal income tax return. On June 7, 1994, petitioners filed an amended return relating to that year. On January 9, 1996,Page: 1 2 3 4 Next
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