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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