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WILLIS v. COMMISSIONER

Docket No. 6456-02L.

86 T.C.M. 506 (2003)

T.C. Memo. 2003-302

Donald G. and Claudia A. Willis v. Commissioner.

United States Tax Court.

Filed November 3, 2003.

Attorney(s) appearing for the Case

Mark H. Westlake, for the petitioners.

Caroline Krivacka, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

SWIFT, Judge:

This case arises from a petition for judicial review timely filed in response to a notice of determination concerning collection action under section 6330.1 The notice of determination relates to petitioners' Federal income tax liabilities for 1992, 1993, 1994, 1995, 1996, and 1997. Petitioners' liability for the underlying taxes, interest, and penalties is not disputed. The...

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