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CRISAN v. COMMISSIONER

Docket No. 11953-02L.

86 T.C.M. 601 (2003)

T.C. Memo. 2003-318

James J. Crisan and Veronica L. Crisan v. Commissioner.

United States Tax Court.

Filed November 17, 2003.

Attorney(s) appearing for the Case

James J. Crisan and Veronica L. Crisan, pro sese.

Michelle M. Lippert, for the respondent.

MEMORANDUM OPINION

HAINES, Judge:

Respondent sent petitioner James Crisan (Mr. Crisan) and petitioner Veronica Crisan (Mrs. Crisan), collectively petitioners, a Notice of Determination Concerning Collection Action(s) under Section 6320 and/or 6330 (notice of determination).1 The issue for decision is whether there was an abuse of discretion in the determination that collection action could proceed for 1998 and 1999 (years in...

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