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DOWNING v. COMMISSIONER

Dkt. No. 6452-05L.

94 T.C.M. 319 (2007)

T.C. Memo. 2007-291

Richard M. Downing v. Commissioner.

United States Tax Court.

September 24, 2007.

Attorney(s) appearing for the Case

B.J. Hickert and Seamus P. Smith, for petitioner.

Charles M. Berlau and Michael L. Boman, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

THORNTON, Judge:

Pursuant to sections 6320(c) and 6330(d), petitioner seeks review of respondent's determination sustaining the filing of a Federal tax lien with respect to petitioner's 1995 and 1999 income tax.1

FINDINGS OF FACT

The parties have stipulated some facts, which we incorporate herein by this reference. When he petitioned the Court, petitioner resided in Kansas...

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