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ECKERT v. COMMISSIONER

Docket No. 1437-03L.

88 T.C.M. 362 (2004)

T.C. Memo. 2004-235

Philip L. and Sara N. Eckert v. Commissioner.

United States Tax Court.

October 13, 2004.

Attorney(s) appearing for the Case

Philip L. and Sara N. Eckert, pro sese.

James A. Kutten, for respondent.

MEMORANDUM OPINION

CARLUZZO, Special Trial Judge:

In a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 dated January 10, 2003, respondent proposed to proceed with collection of petitioners' unpaid 1994 Federal income tax.1 Petitioners object to respondent's proposed collection activity upon the ground that their 1994 Income tax liability has been fully paid.

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