T.C. Memo. 2005-198
UNITED STATES TAX COURT
MEHDI H. HAJIYANI, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4008-04L. Filed August 16, 2005.
Mehdi H. Hajiyani, pro se.
Roger W. Bracken, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Chief Judge: Petitioner, pursuant to section
6330(d),1 seeks review of respondent’s determination to proceed
with collection (by means of levy) of petitioner’s unpaid 1993
1Unless otherwise indicated, all section references are to
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
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