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FIGLER v. COMMISSIONER

Docket No. 16621-02L.

90 T.C.M. 347 (2005)

T.C. Memo. 2005-230

E. Neal Figler v. Commissioner.

United States Tax Court.

October 3, 2005.

Attorney(s) appearing for the Case

E. Neal Figler, pro se.

John Aletta, for respondent.

MEMORANDUM OPINION

WELLS, Judge:

Respondent issued petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination). In response to the notice of determination, petitioner timely filed a petition pursuant to section 6330(d). The issue we must decide is whether respondent may proceed with the collection of petitioner's tax liabilities in issue. All section references are to the Internal Revenue...

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