T.C. Memo. 2007-102
UNITED STATES TAX COURT
JEFFREY CHOU AND CINDY CHOU, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19015-05L. Filed April 25, 2007.
Robert L. Sommers, for petitioners.
Alvah Lavar Taylor, for petitioner Cindy Chou.
Jonathan A. Neumann and Shannon Edelstone, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: This action was commenced in response to
Notices of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330. The issues for decision are
(1) whether the Court should determine petitioners’ tax liability
for 2001 after that liability has been conceded by respondent and
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Last modified: November 10, 2007