John Wesley Winters, Jr. - Page 1

                                 T.C. Memo. 2005-13                                   

                               UNITED STATES TAX COURT                                

                       JOHN WESLEY WINTERS, JR., Petitioner v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11606-03L.            Filed January 27, 2005.               

               John Wesley Winters, Jr., pro se.                                      
               J. Craig Young, for respondent.                                        

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               COHEN, Judge:  This case was commenced in response to a                
          Notice of Determination Concerning Collection Action(s) Under               
          Section 6320 and/or 6330.  The notice of determination sustained            
          a proposed levy with respect to petitioner’s unpaid taxes for               
          1993.  The issue for decision is whether petitioner has shown               
          that his reported tax liability for 1993 was eliminated by losses           

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