T.C. Memo. 2007-59
UNITED STATES TAX COURT
RALPH TASHJIAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14111-05L. Filed March 12, 2007.
Patrick J. Quinn and Bernard P. Kenneally, for petitioner.
Catherine G. Chang, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: The petition in this case was filed in
response to a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 (notice of
determination). After concessions by the parties, the issues for
decision are:
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