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BLOCKER v. COMMISSIONER

Docket No. 3129-04L.

90 T.C.M. 555 (2005)

T.C. Memo. 2005-279

Patricia Ann Blocker, v. Commissioner.

United States Tax Court.

December 1, 2005.

Attorney(s) appearing for the Case

Donald R. Williams, for petitioner.

Daniel N. Price, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge:

This proceeding was commenced in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. The issue for decision is whether respondent correctly assessed petitioner's underlying tax liability, which, in turn, depends on whether the statutory notice for 1989 not received by petitioner was sent to petitioner's last known address.

FINDINGS OF FACT...

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