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KELLER v. COMMISSIONER

Docket No. 000-000A.

92 T.C.M. 114 (2006)

T.C. Memo. 2006-166

Michael Keller v. Commissioner.

United States Tax Court.

August 14, 2006.

Attorney(s) appearing for the Case

Asher B. Bearman, Jaret R. Coles, Jennifer A. Gellner, Terri A. Merriam, and Wendy S. Pearson, for petitioner.

Gregory M. Hahn and Thomas N. Tomashek, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge:

Petitioner filed a petition with this Court in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/ or 6330 for 1991, 1992, and 1993.1 Pursuant to section 6330(d), petitioner seeks review of respondent's determination. The sole issue for decision is whether respondent abused his discretion in sustaining the proposed levy action.

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