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ROYAL v. COMMISSIONER

Dkt. No. 5447-05L.

91 T.C.M. 1002 (2006)

T.C. Memo. 2006-71

Stephen Daryl Royal v. Commissioner.

United States Tax Court.

April 11, 2006.

Attorney(s) appearing for the Case

Stephen Daryl Royal, pro se.

Bradley C. Plovan, for respondent.

MEMORANDUM OPINION

CHIECHI, Judge:

Petitioner filed the petition in this case in response to a notice of determination concerning collection action(s) under section 63201 and/or 6330 (notice of determination).

We must decide whether respondent abused respondent's discretion in determining to proceed with the collection action as determined in the notice of determination with respect to petitioner's taxable years 1997...

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