T.C. Memo. 2004-101
UNITED STATES TAX COURT
SEGUDINO AND DELFA RAZO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16969-02L. Filed April 9, 2004.
David P. Leeper, for petitioners.
Michael W. Bentley and Gordon P. Sanz, for respondent.
MEMORANDUM OPINION
GOEKE, Judge: This proceeding was commenced in response to
a “NOTICE OF DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER
SECTION 6320 AND/OR 6330" (notice of determination). The notice
of determination sustained the Federal tax lien, but suspended
petitioners’ account as “temporarily not collectible”. The issue
for decision is whether it was an abuse of discretion for
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