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CHI WAI v. COMMISSIONER

Docket No. 19316-04L.

92 T.C.M. 181 (2006)

T.C. Memo. 2006-179

Chi Wai, v. Commissioner.

United States Tax Court.

August 29, 2006.

Attorney(s) appearing for the Case

John S. Harper, for petitioner.

Cleve Lisecki, for respondent.

MEMORANDUM OPINION

NIMS, Judge:

Petitioner petitioned the Court under section 6330(d)1 to review the determination of the Internal Revenue Service's Office of Appeals sustaining a proposed levy on petitioner's property related to petitioner's year 2000 Federal income tax liability. Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect at relevant times. Petitioner resided in...

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