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FINE v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 23553-15L.

T.C. Memo. 2016-217

RICHARD ISAAC FINE AND MARYELLEN OLMAN-FINE, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed November 29, 2016.

Attorney(s) appearing for the Case

Richard Isaac Fine and Maryellen Olman-Fine, pro sese.

Steven Mitchell Roth , for respondent.

MEMORANDUM OPINION

In this collection due process (CDP) case, petitioners seek review pursuant to sections 6320(c) and 6330(d)(1)1 of the determination by the Internal Revenue Service (IRS or respondent) to uphold the filing of a notice of Federal tax lien (NFTL). Respondent has moved for summary...

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