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HOLLIDAY v. COMMISSIONER

Docket No. 6330-04L.

90 T.C.M. 390 (2005)

T.C. Memo. 2005-240

Tim W. Holliday, v. Commissioner.

United States Tax Court.

October 12, 2005.

Attorney(s) appearing for the Case

Tim W. Holliday, pro se.

Laurel M. Costen, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge:

The petition in this case was filed in response to a Notice of Determination Concerning Collection Actions(s) Under Section 6320 and/or 6330 (notice of determination).1 Pursuant to section 6330(d), petitioner seeks review of respondent's determination. The issues for decision are: (1) Whether petitioner's underlying tax liability for 1999 is properly at issue; (2) whether...

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