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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