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COX v. COMMISSIONER

Docket Nos. 21733-03L, 14693-04L.

126 T.C. 237 (2006)

126 T.C. No. 13

LOUIS A. AND CHRISTINE COX, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 3, 2006.

Attorney(s) appearing for the Case

Theodore H. Merriam and Kevin A. Planegger, for petitioners.

Frederick J. Lockhart, Jr., for respondent.

OPINION

WHERRY, Judge:

These consolidated cases arise from petitions for judicial review filed in response to Notices of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330.1 The issue for decision is whether respondent may proceed with collection of income tax liabilities for years 2000, 2001, and 2002.

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