T.C. Memo. 2006-20
UNITED STATES TAX COURT
JOHN F. AND CAROLYN J. JOSEPH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6799-04L. Filed February 8, 2006.
John F. Joseph, pro se.
Paul Butler, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: Respondent sent petitioners a Notice of
Determination Concerning Collection Action(s) Under Section 63201
and/or 6330 in which respondent determined to proceed with
collection by levy of petitioners’ income taxes for 1998-2001.
1Unless otherwise indicated, section references are to the
Internal Revenue Code in effect at relevant times. Rule
references are to the Tax Court Rules of Practice and Procedure.
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