T.C. Memo. 2004-204
UNITED STATES TAX COURT
KEVIN THOMPSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3947-03L. Filed September 8, 2004.
Kevin Thompson, pro se.
John F. Driscoll, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge: This case arises from respondent’s issuance
of a Notice of Determination Concerning Collection Action(s)
Under Section 6320 and/or 6330 for petitioner’s taxable year
1997. Respondent has filed both a notice of Federal tax lien
filing and a notice of intent to levy against petitioner for his
1997 unpaid tax liability. The issues for decision are: (1)
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