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SHERWOOD v. COMMISSIONER

Docket No. 21913-04L.

90 T.C.M. 512 (2005)

T.C. Memo. 2005-268

Wesley Sherwood v. Commissioner.

United States Tax Court.

November 21, 2005.

Attorney(s) appearing for the Case

Wesley Sherwood, pro se;

S. Mark Barnes, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

On October 14, 2004, respondent sent petitioner a Notice of Determination Concerning Collection Action(s) Under Sections 6320 and/or 6330,1 in which respondent determined that it was appropriate to file a notice of lien with respect to petitioner's unpaid income taxes, penalties, and interest for 1997-2002.

The issues for decision are:

1. Whether we have jurisdiction...

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