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FREY v. COMMISSIONER

Docket No. 2703-03L.

87 T.C.M. 1170 (2004)

T.C. Memo. 2004-87

Gerald L. and Jessica P. Frey v. Commissioner.

United States Tax Court.

Filed March 26, 2004.

Attorney(s) appearing for the Case

Gerald L. and Jessica P. Frey, pro sese.

Veena Luthra, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge.

Petitioners filed the petition in this case in response to a notice of determination concerning collection action(s) under section 6320 and/or 6330 (notice of determination).

We must decide whether respondent abused respondent's discretion in determining to proceed with the collection action as determined in the notice of determination with respect to petitioners' taxable years 1996, 1997, and...

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