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PLESS v. COMMISSIONER

Docket No. 1917-03L.

87 T.C.M. 845 (2004)

T.C. Memo. 2004-24

Vicki S. Pless and Coy E. Pless, Jr. v. Commissioner.

United States Tax Court.

Filed February 3, 2004.

Attorney(s) appearing for the Case

Vicki S. Pless and Coy E. Pless, Jr., pro se.

James R. Rich, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge:

This case was commenced in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 and a Notice of Determination Concerning Your Request for Relief from Joint and Several Liability Under Section 6015. The issue for decision is whether there was an abuse of discretion in issuing the notices of determination without conducting a hearing requested by petitioners...

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