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TATUM, JR. v. COMMISSIONER

Docket No. 1126-01L.

85 T.C.M. 1200 (2003)

T.C. Memo. 2003-115

Carter B. Tatum, Jr. and Barbara B. Tatum v. Commissioner.

United States Tax Court.

Filed April 22, 2003.

Attorney(s) appearing for the Case

David L. Miller, for the petitioners.

Nina P. Ching, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

This case arises from petitioners' request for our review (pursuant to section 63301) of respondent's decision to proceed with collection by levy with respect to their outstanding 1990 and 1991 tax liabilities. The issue to be resolved is whether such decision by respondent constitutes an abuse of discretion.

FINDINGS OF FACT

Some of the facts have been...

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