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ABELEIN v. COMMISSIONER

Dkt. No. 24804-04L.

93 T.C.M. 857 (2007)

T.C. Memo. 2007-24

Daniel O. Abelein v. Commissioner.

United States Tax Court.

February 6, 2007.

Attorney(s) appearing for the Case

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 6330 (notice of determination) for 1982 through 1986.1 Pursuant to section 6330(d), petitioner seeks review of respondent's determination. The issue for decision is whether respondent abused his discretion in sustaining the proposed collection...

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