FRANKLIN v. COMMISSIONER

Dkt. No. 18722-04L.

93 T.C.M. 870 (2007)

T.C. Memo. 2007-26

Franklin and Janetta Hubbart v. Commissioner.

United States Tax Court.

February 6, 2007.


Attorney(s) appearing for the Case

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

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


MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge:

Petitioners filed a petition with this Court in response to a Notice of Determination Concerning Collection Actions Under Section 6320 (notice of determination) for 1981 through 1986.1 Pursuant to section 6330(d), petitioners seek review of respondent's determination. The issue for decision is whether respondent abused his discretion in sustaining the proposed collection...

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