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LEAHY v. COMMISSIONER

Docket No. 17199-06L.

129 T.C. 71 (2007)

129 T.C. No. 8

MICHAEL PATRICK AND DEBYE LEE LEAHY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 17, 2007.

Attorney(s) appearing for the Case

Michael Patrick and Debye Lee Leahy, pro sese.

John R. Bampfield, for respondent.

OPINION

RUWE, Judge:

Pursuant to section 6330(d), petitioners filed a petition for review of respondent's Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination).1 Petitioners request that this case be conducted under section 7463(f)(2), which provides for what are commonly referred to as "small tax case" or "S case" procedures...

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