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URBANO v. COMMISSIONER

Docket No. 14466-02L.

122 T.C. 384 (2004)

122 T.C. No. 22

WILLIAM F. URBANO AND FLOTA L. URBANO, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 10, 2004.

Attorney(s) appearing for the Case

William F. Urbano and Flota L. Urbano, pro sese.

Karen Nicholson Sommers, for respondent.

OPINION

LARO, Judge:

This case is before the Court for decision without trial. See Rule 122.1 Petitioners petitioned the Court under section 6330(d)(1), as made applicable by section 6320(c), to review the determination of respondent's Office of Appeals (Appeals) sustaining respondent's filing of a notice of Federal tax lien (NFTL). Respondent filed the NFTL to secure the payment of $31,455.49 shown in his records to be...

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