T.C. Memo. 2006-43
UNITED STATES TAX COURT
LEONARD O. PARKER, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4053-03L. Filed March 15, 2006.
Leonard O. Parker, Jr. pro se.
Hieu C. Nguyen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HAINES, Judge: This is a case under sections 6320 and
6330.1 Petitioner failed to pay income tax liabilities for 1992,
1993, and 1994 (years at issue). As a result, respondent filed a
Notice of Federal Tax Lien (NFTL). The issues for decision are:
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended. Amounts are rounded to
the nearest dollar.
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