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LINDLEY v. COMMISSIONER

Docket No. 6657-05L.

92 T.C.M. 363 (2006)

T.C. Memo. 2006-229

William H. and Jo Anne Lindley v. Commissioner.

United States Tax Court.

October 26, 2006.

Attorney(s) appearing for the Case

Asher B. Bearman, Jaret R. Coles, Jennifer A. Gellner, Terri A. Merriam, and Wendy S. Pearson, for petitioners.

Gregory M. Hahn and Thomas N. Tomashek, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge:

Petitioners filed a petition with this Court in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination) for 1987 through 1990.1 Pursuant to section 6330(d), petitioners seek review of respondent's determination. The issue for decision is whether respondent abused his discretion in sustaining the proposed...

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