T.C. Memo. 2005-48
UNITED STATES TAX COURT
DONNIE FRANCIS SCHROEDER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1157-04L. Filed March 15, 2005.
Donnie Schroeder, pro se.
Alan J. Tomsic, for respondent.
MEMORANDUM OPINION
LARO, Judge: Petitioner petitioned the Court under section
6330(d) to review a determination of the Commissioner’s Office of
Appeals (Appeals) sustaining respondent’s proposed levy upon his
property.1 Respondent proposed the levy to collect 1995 and 1996
Federal income taxes with additions thereto totaling
1 Unless otherwise noted, section references are to the
applicable versions of the Internal Revenue Code.
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