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SINGER v. COMMISSIONER

Docket No. 147-04L.

90 T.C.M. 67 (2005)

T.C. Memo. 2005-175

Donald A. Singer and Virginia M. Singer v. Commissioner

United States Tax Court.

July 18, 2005.

Attorney(s) appearing for the Case

Donald A. Singer and Virginia M. Singer, pro sese.

Pamela L. Mable, for respondent.

MEMORANDUM OPINION

WELLS, Judge:

Respondent issued petitioners a Notice of Determination Concerning Collection Action(s) under Section 6320 and/or 6330 (notice of determination).1 In response to that notice, petitioners timely filed a petition for lien or levy action under Code section 6320(c) or 6330(d). We review for abuse of discretion respondent's notice of determination.

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