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CALL v. COMMISSIONER

Docket No. 19609-03L.

90 T.C.M. 601 (2005)

T.C. Memo. 2005-289

Harold E. Call v. Commissioner.

United States Tax Court.

December 15, 2005.

Attorney(s) appearing for the Case

Harold E. Call, pro se.

Alan J. Tomsic, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge:

This case arises from a petition for judicial review filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330.1 The issues for decision are: (1) Whether respondent may proceed with collection action as so determined, and (2) whether the Court, sua sponte, should impose a penalty under section 6673.

FINDINGS OF...

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