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McCORKLE v. COMMISSIONER

Docket No. 1433-03L.

124 T.C. 56 (2005)

124 T.C. No. 5

WILLIAM J. McCORKLE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 24, 2005.

Attorney(s) appearing for the Case

William J. McCorkle, pro se.

Pamela L. Mable, for respondent.

OPINION

HALPERN, Judge:

This case is before the Court to review a determination made by respondent's Appeals Office (Appeals) that respondent was warranted in filing a notice of Federal tax lien (the notice of Federal tax lien or NFTL) against petitioner with respect to his Federal income tax liability for 1996 (1996 tax liability). We review that determination pursuant to sections 6320(c) and 6330(d)(1).1 Petitioner assigns...

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