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SCHWARTZ v. COMMISSIONER

Docket No. 2914-06L.

128 T.C. 6 (2007)

128 T.C. No. 2

THEODORE C. AND DENISE M. SCHWARTZ, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 14, 2007.

Attorney(s) appearing for the Case

Theodore C. and Denise M. Schwartz, pro sese.

Michele E. Craythorn, for respondent.

OPINION

RUWE, Judge:

This case is before the Court for judicial review of a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (determination letter). The petition was filed pursuant to section 6330(d).1 Petitioners requested that this case be conducted under section 7463, which provides for what are commonly referred to as "small tax case" or...

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