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EVERETT ASSOCIATES, INC. v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 26685-07L.

T.C. Memo. 2012-143

EVERETT ASSOCIATES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 17, 2012.

Attorney(s) appearing for the Case

Donald F. Payne (an officer), for petitioner.

James A. Whitten , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GOEKE, Judge.

Pursuant to section 6330(d),1 petitioner seeks review of a notice of determination sustaining respondent's proposed levy. Respondent's collection activity stems from alleged deficiencies in petitioner's employment taxes.2 Petitioner challenges the propriety of respondent's collection actions by asserting, primarily, that respondent received and...

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