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WILLIAM J. v. COMMISSIONER

Dkt. No. 7029-03L.

93 T.C.M. 1060 (2007)

T.C. Memo. 2007-77

William J. and Lois J. DiCindio v. Commissioner.

United States Tax Court.

April 2, 2007.

Attorney(s) appearing for the Case

William J. and Lois J. DiCindio, pro se.

Donald M. Brachfeld, for respondent.

MEMORANDUM OPINION

COLVIN, Chief Judge:

Respondent sent a Notice of Determination Concerning Collection Action(s) Under Section 63201 and/or 6330 to petitioners in which respondent determined that it was appropriate to sustain collection action with respect to petitioners' unpaid income taxes for 1985-89 and 1991-2001 (the years in issue).2 Thereafter petitioners timely filed a petition in which they...

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