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THOMAS v. COMMISSIONER

Docket No. 3263-02L.

86 T.C.M. 216 (2003)

T.C. Memo. 2003-231

Antonio and Ernestine Thomas v. Commissioner.

United States Tax Court.

Filed August 1, 2003.

Attorney(s) appearing for the Case

Antonio L. and Ernestine Thomas, pro se.

Monica D. Armstrong, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GALE, Judge:

This case arises from a petition filed pursuant to sections 6320(c) and 6330(d)(1)(A).1 After concessions,2 the issue for decision is whether respondent's determination to proceed with a collection with respect to petitioners' Federal income tax liabilities for 1991 should be sustained. We hold that it should.

FINDINGS OF FACT

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