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MANKO v. COMMISSIONER

Docket No. 24124-04L.

126 T.C. 195 (2006)

126 T.C. No. 9

BERNHARD F. AND CYNTHIA G. MANKO, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 20, 2006.

Attorney(s) appearing for the Case

Irwin S. Meyer, for petitioner Bernhard F. Manko.

Hugh Janow, for petitioner Cynthia G. Manko.

Gerard Mackey, for respondent.

OPINION

KROUPA, Judge:

Petitioners seek review under section 6330(d)1 of respondent's determination to proceed with a proposed levy to collect petitioners' Federal income tax liabilities for 1988 and 1989 (the years at issue). We are asked to decide whether respondent may proceed with collection of these liabilities, which respondent assessed without first issuing petitioners a notice of deficiency (deficiency notice)...

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