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BRIAN v. COMMISSIONER

Dkt. No. 8587-04L.

89 T.C.M. 1499 (2005)

T.C. Memo. 2005-156

Brian and Tina Nicklaus v. Commissioner.

United States Tax Court.

June 27, 2005.

Attorney(s) appearing for the Case

Brian Nicklaus and Tina Nicklaus, pro se;

Aimee R. Lobo-Berg, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent sent petitioners a Notice of Determination Concerning Collection Action(s) Under Sections 6320 and/or 6330 (the levy determination) on April 15, 2004, in which respondent determined to proceed with collection by levy from both petitioners of income tax liabilities for 1993 and 1994 and from Brian Nicklaus for 1995-2000.

The sole issue for decision is whether respondent's determination...

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