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MANN v. COMMISSIONER

Docket No. 6263-00L.

83 T.C.M. 1259 (2002)

T.C. Memo. 2002-48

Terry K. Mann v. Commissioner.

United States Tax Court.

Filed February 21, 2002.

Attorney(s) appearing for the Case

Joyce Griggs, for the petitioner.

Ross M. Greenberg, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Petitioner petitioned the Court under section 6330(d).1 We must decide whether (1) respondent abused his discretion under section 6330 and (2) petitioner is liable for a section 6673(a)(1) penalty.

FINDINGS OF FACT

Most facts were stipulated. We incorporate herein by this reference the parties' stipulation of facts and the accompanying exhibits. Petitioner...

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