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HOYLE v. COMMISSIONER OF INTERNAL REVENUE

No. 7217-04L.

131 T.C. No. 13

MARTIN DAVID HOYLE, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States tax Court.

Filed December 3, 2008.

Martin David Hoyle, pro se.

Beth Nunnink, for respondent.

OPINION

WELLS, Judge.

Respondent sent a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination) to petitioner with respect to a lien filed to collect petitioner's unpaid tax liability for 1993. In response, petitioner timely filed a petition pursuant to section 6330(d),1 seeking review of respondent...

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