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FOLLUM v. COMMISSIONER

Dkt. No. 7936-03L.

93 T.C.M. 1407 (2007)

T.C. Memo. 2007-270

Warren R. Follum, Petitioner v. Commissioner.

United States Tax Court.

June 25, 2007.

Attorney(s) appearing for the Case

Warren Richard Follum, pro se.

James R. Rich, for respondent.

MEMORANDUM OPINION

WELLS, Judge:

Petitioner seeks review, pursuant to section 6320,1 of respondent's determination to proceed with the collection of petitioner's income tax liabilities for the 1990, 1991, 1992, and 1993 taxable years. The issues we must decide are whether petitioner's claim that notice and demand for payment was not sent to his last known address is barred by the doctrine of res judicata; whether the period of...

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