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DAVID v. COMMISSIONER

Dkt. No. 14621-05L.

93 T.C.M. 1037 (2007)

T.C. Memo. 2007-69

David and Monika Zisskind v. Commissioner.

United States Tax Court.

March 27, 2007.

Attorney(s) appearing for the Case

Timothy J. Burke, for petitioners.

Louise R. Forbes, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge:

Petitioners filed a petition with this Court in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination) for 1999.1 Pursuant to section 6330(d), petitioners seek review of respondent's determination. The issues for decision are: (1) Whether petitioners are liable for an addition to tax under section 6651...

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