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PARIKH v. COMMISSIONER

Docket No. 14666-02L.

86 T.C.M. 720 (2003)

T.C. Memo. 2003-341

Bharat S. Parikh v. Commissioner.

United States Tax Court.

Filed December 16, 2003.

Attorney(s) appearing for the Case

Bharat S. Parikh, pro se.

William J. Gregg and Warren P. Simonsen, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

The issue for decision is whether respondent may proceed with collection relating to petitioner's 1988 and 1992 tax liabilities.

FINDINGS OF FACT

Petitioner failed to file a 1988 Federal income tax return. Respondent filed a substitute return relating to that year and sent petitioner a notice of deficiency. In response, petitioner initiated a proceeding, Parikh

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