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SCIOLA v. COMMISSIONER

Docket No. 11876-02L.

86 T.C.M. 681 (2003)

T.C. Memo. 2003-334

Anthony Sciola v. Commissioner.

United States Tax Court.

Filed December 4, 2003.

Attorney(s) appearing for the Case

Anthony Sciola, pro se.

Louise R. Forbes, for the respondent.

MEMORANDUM OPINION

GOLDBERG, Special Trial Judge:

This case arises from a petition for judicial review filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330.1 The issue for decision is whether respondent may proceed with collection of tax liabilities for the years 1995 and 1996.

Some of the facts have been stipulated and are so found. The stipulation of facts and...

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