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WINSTON O. v. COMMISSIONER

Docket No. 14601-01L.

86 T.C.M. 62 (2003)

T.C. Memo. 2003-205

Winston O. and Paulet P. Smith v. Commissioner.

United States Tax Court.

Filed July 15, 2003.

Attorney(s) appearing for the Case

Winston O. and Paulet P. Smith, pro sese.

Lorianne D. Masano, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

The issue for decision is whether respondent may proceed with his proposed collection activity relating to petitioners' 1982, 1983, 1986, and 1987 tax liabilities.

FINDINGS OF FACT

On December 7, 1998, petitioners and respondent executed an installment agreement, and petitioners signed Form 900, Tax Collection Waiver, relating to petitioners' 1982, 1983, 1986, and 1987 tax liabilities...

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