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HUMPHREY v. COMMISSIONER

Docket No. 19295-03L.

92 T.C.M. 417 (2006)

T.C. Memo. 2006-242

Robert C. and Patricia C. Humphrey, v. Commissioner.

United States Tax Court.

November 9, 2006.

Attorney(s) appearing for the Case

Brian Gary Isaacson and Don Paul Badgley, for petitioner;

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

MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge:

Petitioners filed a petition with this Court in response to Notices of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 for 2000. Pursuant to section 6330(d), petitioners seek review of respondent's determinations.1 All references to petitioner in the singular are to petitioner Robert C. Humphrey. After concessions,2

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