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GINALSKI v. COMMISSIONER

Dkt. No. 12522-03L.

87 T.C.M. 1249 (2004)

T.C. Memo. 2004-104

June H. Ginalski v. Commissioner.

United States Tax Court.

Filed April 22, 2004.

Attorney(s) appearing for the Case

June H. Ginalski, pro se;

Rachel J. Zepeda, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

This matter arises, under section 6320,1 out of respondent's filing of a Notice of Federal Tax Lien with respect to petitioner's 1993 and 1994 income tax liabilities. The sole issue presented for our consideration is whether petitioner is entitled to question the underlying merits of her 1993 and 1994 income tax liabilities.

FINDINGS OF FACT

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