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FARIS v. COMMISSIONER

Docket No. 9542-05L.

92 T.C.M. 451 (2006)

T.C. Memo. 2006-254

Denis J. Faris and Carolyn M. Faris v. Commissioner.

United States Tax Court.

November 27, 2006.

Attorney(s) appearing for the Case

Denis J. Faris and Carolyn M. Faris, pro sese.

Kelley A. Blaine, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Pursuant to section 6330(d),1 petitioners seek review of respondent's determination to proceed with collection of their 1997 and 1998 income tax liabilities. The issues for decision are: (1) Whether respondent may proceed with collection of petitioners' 1997 and 1998 income tax liabilities; and (2) whether petitioners are liable for a penalty pursuant to section 6673.

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