WETZEL v. COMMISSIONER

Docket No. 20579-03L.

90 T.C.M. 266 (2005)

T.C. Memo. 2005-211

Thiele L. Wetzel v. Commissioner.

United States Tax Court.

September 12, 2005.


Attorney(s) appearing for the Case

Thiele L. Wetzel, pro se.

Lorraine D. Massano, for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent sent petitioner a Notice of Determination Concerning Collection Action Under Section 6320 (the lien determination) in which respondent determined that the notice of Federal tax lien regarding petitioner's income tax liabilities for 1994-99 was appropriate and would not be withdrawn.

The issues for decision are:

1. Whether petitioner may dispute the existence or amount of his...

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