WINGERT v. COMMISSIONER

Docket No. 9433-01L.

85 T.C.M. 1488 (2003)

T.C. Memo. 2003-172

John Joseph Wingert v. Commissioner.

United States Tax Court.

Filed June 11, 2003.


Attorney(s) appearing for the Case

John Joseph Wingert, pro se.

Ann M. Welhaf and Jeffrey E. Gold, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge.

Respondent sent petitioner a Notice of Determination Concerning Collection Action(s) Under Sections 6320 and/or 6330 (the lien or levy determination) on July 13, 2001, in which respondent determined to proceed with collection from petitioner of his tax liabilities for 1994, 1995, and 1996 (1994-96). The issue for decision is whether respondent's determination was an abuse of discretion. We hold that...

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