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ERTZ v. COMMISSIONER

Dkt. No. 20336-04L.

93 T.C.M. 696 (2007)

T.C. Memo. 2007-15

Donald Ertz v. Commissioner.

United States Tax Court.

January 24, 2007.

Attorney(s) appearing for the Case

Jaret R. Coles and Terri A. Merriam, for petitioner.

Gregory M. Hahn and Thomas N. Tomashek, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge:

Petitioner filed a petition with this Court in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination) for 1982 through 1988, 1993, and 1997.1 Pursuant to section 6330(d), petitioner seeks review of respondent's determination. The issues for decision are: (1) Whether respondent abused his discretion in...

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