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HARRELL v. COMMISSIONER

Docket No. 4063-02L.

86 T.C.M. 378 (2003)

T.C. Memo. 2003-271

Edward H. and Anne G. Harrell v. Commissioner.

United States Tax Court.

Filed September 17, 2003.

Attorney(s) appearing for the Case

Guy C. Crowgey, for the petitioners.

Mary Ann Waters, for the respondent.

MEMORANDUM OPINION

NIMS, Judge:

This case arises from a petition for judicial review filed in response to a "NOTICE OF DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330" dated January 22, 2002 (Notice of Determination). The Notice of Determination dealt with petitioners' income tax liabilities for tax years 1991, 1992, 1993, and 1999. The parties agree that the underlying tax liabilities are no longer in dispute.

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