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KADILLAK v. COMMISSIONER

Docket No. 2860-04L.

127 T.C. 184 (2006)

127 T.C. No. 13

ANTHONY J. KADILLAK, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 7, 2006.

Attorney(s) appearing for the Case

Don Paul Badgley, Duncan C. Turner, and Brian G. Isaacson, for petitioner.

Kirk M. Paxson, Julie L. Payne, and William C. Schmidt, for respondent.

OPINION

HAINES, Judge:

Petitioner filed a petition with this Court in response to Notices of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 for 2000 and 2001 (years at issue). Pursuant to section 6330(d), petitioner seeks review of respondent's determinations.1

The remaining issues for decision are:

(1) Whether petitioner's section...

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