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REYNOLDS v. COMMISSIONER

Docket No. 17810-04L.

92 T.C.M. 260 (2006)

T.C. Memo. 2006-192

Woodrow Reynolds v. Commissioner.

United States Tax Court.

September 11, 2006.

Attorney(s) appearing for the Case

Woodrow Reynolds, pro se.

Timothy S. Murphy, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge.

This case is before the Court on a petition for judicial review of a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. The issues for decision are: (1) Whether respondent may proceed with collection action as so determined; and (2) whether the Court should sua sponte impose a penalty pursuant to section 6673(a).1

FINDINGS OF...

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