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WRIGHT v. COMMISSIONER

Docket No. 4311-04L.

90 T.C.M. 615 (2005)

T.C. Memo. 2005-291

Gary Wright v. Commissioner.

United States Tax Court.

December 20, 2005.

Attorney(s) appearing for the Case

Gary Wright, pro se.

Alan J. Tomsic, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge:

This case arises from a petition for judicial review filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330.1 The issues for decision are: (1) Whether respondent may proceed with collection action as so determined, and (2) whether the Court, sua sponte, should impose a penalty under section 6673.

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