Raymond and Cynthia Turner-Simmons - Page 1

                                 T.C. Memo. 2005-135                                  

                               UNITED STATES TAX COURT                                

                 RAYMOND AND CYNTHIA TURNER-SIMMONS, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3151-03L.             Filed June 9, 2005.                   

               Raymond and Cynthia Turner-Simmons, pro sese.                          
               John W. Sheffield III, for respondent.                                 

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               HALPERN, Judge:  This case is before the Court to review a             
          determination made by respondent’s Appeals Office (Appeals) that            
          respondent may proceed to collect by levy unpaid taxes with                 
          respect to petitioners’ 1995 tax year (1995).  We review that               
          determination pursuant to section 6330(d)(1).                               

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