§63201

We hold that we sustain those determinations.

We hold that she does .

MEMORANDUM OPINION CHIECHI, Judge: This case arises from a petition filed in response to a notice of determination concerning collection action(s) under section 63201 and/or 6330 (notice of determina- tion).

MEMORANDUM FINDINGS OF FACT AND OPINION CHIECHI, Judge: This case arises from a petition filed in response to a notice of determination concerning collection action(s) under section 63201 and/or 6330 (notice of determina- 1All section references are to the Internal Revenue Code at all relevant times.

MEMORANDUM FINDINGS OF FACT AND OPINION FRIED, Special Trial Judge: In a Notice of Determination Concerning Collection Action(s) Under Section 63201 and/or 6330 (notice of determination), dated September 20, 2022, respondent determined that it was appropriate to collect by levy petitioner’s outstanding 2016 federal income tax liability (underlying liability).

MEMORANDUM OPINION PARIS, Judge: This case is before the Court on a Petition for review of Notices of Determination Concerning Collection Action(s) Under Section 63201 and/or 6330 and Abatement of Interest Under Section 6404 sustaining notices of intent to levy for petitioners’ 2004 and 2005 tax years and sustaining the filing of Notices of Federal Tax Lien (NFTLs) for petitioners’ 2004 and 2005 tax years (collectively, Notices).

MEMORANDUM OPINION KERRIGAN, Chief Judge: The Petition in this case was filed in response to a Notice of Determination Concerning Collection Action(s) under IRC Section 63201 and/or 6330 (notice of determination) dated August 20, 2019, sustaining the filing of a Notice of Federal Tax Lien (NFTL) and proposed levy pertaining to an assessment, based on an affected items notice of deficiency dated October 13, 2017.

MEMORANDUM OPINI N MARVEL, Judge : Petitioners petitioned this Court in response to respondent's Notice of Determination Concerning Collection Action(s) Under Section 63201 and/or 6330 for 199 8 'Unless otherwise indicated, all se tion references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure .

MEMORANDUM OPINION GERBER, Judge: Respondent moved for summary judgment in this section 63201 collection proceeding involving the filing of 7 a notice of Federal tax lien (NFTL) .

MEMORANDUM FINDINGS OF FACT AND OPINION CHIECHI, Judge : This case arises from a petition and an amended petition filed in response to a notice of determination concerning collection action(s) under section 63201 and/or 6330 (notice of determination) .

MEMORANDUM FINDINGS OF FACT AND OPINION COLVIN, Chief Judge: Respondent sent a Notice of Determination Concerning Collection Action(s) Under Section 63201 and/or 6330 to petitioner with respect to a proposed levy to collect petitioner’s unpaid income taxes for tax years 1989, 1 Section references are to the Internal Revenue Code as amended.

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 1 Unless otherwise indicated, section references are to the Internal Revenue Code as amended.

MEMORANDUM FINDINGS OF FACT AND OPINION COLVIN, Judge: Respondent sent a Notice of Determination Concerning Collection Action(s) Under Section 63201 (Lien) and/or 6330 (Levy) to petitioner in which respondent determined that it was appropriate to sustain respondent’s collection action with 1 Section references are to the Internal Revenue Code as amended and in effect for the years in issue.

MEMORANDUM FINDINGS OF FACT AND OPINION GERBER, Chief Judge: On January 2, 2003, respondent sent petitioner a Notice of Determination Concerning Collection Action(s) Under Section 63201 and/or 6330 (notice of 1 Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code in effect for the years at issue.

MEMORANDUM FINDINGS OF FACT AND OPINION GERBER, Chief Judge: Respondent, on February 21, 2002, sent Mark Fowler (petitioner) a Notice of Determination Concerning Collection Action(s) Under Section 63201 and/or 6330, in which respondent sustained the filing of a Federal tax lien for 1 Unless otherwise indicated, all section references are to the Internal Revenue Code.

MEMORANDUM OPINION CARLUZZO, Special Trial Judge: On July 6, 1999, respondent issued to petitioner a Notice of Determination Concerning Collection Action(s) Under Section 63201 and/or 6330 for unpaid 1 Section references are to the Internal Revenue Code of 1986, as amended and in effect at the time the petition was filed.

MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge: On March 28, 2002, respondent mailed to petitioner a Notice of Determination Concerning Collection Action(s) Under Section 63201 and/or 6330 (notice of 1Section references are to the Internal Revenue Code of 1986, as amended and in effect at the time the petition was filed.