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DOSTAL v. COMMISSIONER

Docket No. 13090-04L.

90 T.C.M. 496 (2005)

T.C. Memo. 2005-264

Joseph G. Dostal v. Commissioner.

United States Tax Court.

November 16, 2005.

Attorney(s) appearing for the Case

Robert M. Clegg, for petitioner;

Catherine L. Campbell, for respondent.

MEMORANDUM OPINION

WHALEN, Judge:

Respondent issued a notice of determination concerning collection action(s) under section 6320 and/or 6330 (notice of determination) sustaining a levy on petitioner's property to collect unpaid taxes for taxable years 2000 and 2001. (Section references in this opinion are to the Internal Revenue Code, as amended, unless stated otherwise.) The issue for decision is whether the Appeals officer who made the determination abused...

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