T.C. Memo. 2005-257
UNITED STATES TAX COURT
JAMES MURDEN WILCOX, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5444-04L. Filed November 1, 2005.
James Murden Wilcox, pro se.
Marty J. Dama, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Petitioner filed a petition in response to
respondent’s Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 (Notice of
Determination).1 The sole issue for decision is whether
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended, and all Rule references are
to the Tax Court Rules of Practice and Procedure.
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