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MARTIN v. COMMISSIONER

Docket No. 13419-02L.

87 T.C.M. 818 (2004)

T.C. Memo. 2004-14

Alfred J. Martin v. Commissioner.

United States Tax Court.

Filed January 20, 2004.

Attorney(s) appearing for the Case

Patricia Tucker, for the petitioner.

Anne W. Durning and James E. Cannon, for the respondent.

SUPPLEMENTAL MEMORANDUM OPINION

MARVEL, Judge.

On November 7, 2003, pursuant to Rule 161, petitioner filed a timely Motion for Reconsideration of this Court's Memorandum Opinion in Martin v. Commissioner [Dec. 55,319(M)], T.C. Memo. 2003-288 (Martin II).1

In Martin II, we affirmed respondent's determination to proceed with collection by levy, and, as relevant to our discussion...

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