ENOS v. COMMISSIONER

Docket No. 11630-01L.

123 T.C. 284 (2004)

123 T.C. No. 17

JOSEPH F. AND CAROLINE ENOS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 27, 2004.


Attorney(s) appearing for the Case

Hans A. Stoeckler, for petitioners.

D. Sean McMahon, for respondent.


OPINION

WELLS, Judge:

The petition in the instant case was filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination).1 In the notice of determination, respondent determined that collection should proceed against petitioners to collect a liability for accrued interest on petitioners' tax liabilities for 1971.

The issues to be decided are...

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