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FREIJE v. COMMISSIONER

Docket No. 932-02L.

125 T.C. 14 (2005)

125 T.C. No. 3

JOSEPH PAUL FREIJE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 14, 2005.

Attorney(s) appearing for the Case

Joseph Paul Freije, pro se.

Diane L. Worland, for respondent.

GALE, Judge:

Pursuant to section 6330(d),1 petitioner seeks review of respondent's determination to proceed with collection by levy of income tax liabilities with respect to petitioner's 1997, 1998, and 1999 taxable years. The issue for decision is whether respondent may proceed with proposed levies for liabilities not conceded by him for 1998 and 1999.

FINDINGS OF FACT

Some of the facts have been stipulated and...

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