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DUNHAM v. COMMISSIONER

Docket No. 7029-02L.

86 T.C.M. 344 (2003)

T.C. Memo. 2003-260

James Benson Dunham and Melanie A. Dunham v. Commissioner.

United States Tax Court.

Filed September 8, 2003.

Attorney(s) appearing for the Case

Jerry Arthur Jewett, for the petitioners.

Michelle M. Lippert, for the respondent.

MEMORANDUM OPINION

HAINES, Judge:

The petition in this case was filed in response to the Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. After concessions,1 the issues for decision are whether respondent abused his discretion in determining that collection action could proceed for 1997 and whether the Court should impose a penalty under section 6673.

Unless otherwise indicated,...

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