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JOHNSON v. COMMISSIONER

Docket No. 12616-00L.

117 T.C. 204 (2001)

117 T.C. No. 18

DAVID J. AND JO DENA JOHNSON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 30, 2001.

Attorney(s) appearing for the Case

David J. and Jo Dena Johnson, pro se.

Horace Crump, for respondent.

OPINION

COLVIN, Judge:

On November 2, 2000, respondent sent petitioners a notice of determination concerning collection action(s) under sections 6320 and/or 63301 (the lien or levy determination), in which respondent determined to proceed with collection from petitioners of the frivolous return penalty for 1994, 1995, and 1996. In this opinion we decide:

(1) Whether we have jurisdiction under section 6330(d)(1...

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