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JERRY v. COMMISSIONER

Docket No. 18716-02L.

87 T.C.M. 1251 (2004)

T.C. Memo. 2004-106

Jerry B. and Donna E. Clawson v. Commissioner.

United States Tax Court.

Filed April 23, 2004.

Attorney(s) appearing for the Case

Mitchell I. Horowitz, for petitioners.

Michael Pesavento, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge:

This proceeding was commenced in response to a Notice of Determination Concerning Collection Action Under Section 6330 (notice of determination). The notice of determination sustained a proposed levy with respect to petitioners' unpaid income tax liabilities for 1999 and 2000. The issue for decision is whether the Appeals officer abused his discretion by sustaining a proposed levy to collect petitioners...

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