Thomas J. and Bonnie F. Ratke - Page 1

                                 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,                  

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