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PAZZO PAZZO, INC. v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 6844-15L, 6845-15L, 6846-15L, 6848-15L.

T.C. Memo. 2017-12

PAZZO PAZZO, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed January 10, 2017.

Attorney(s) appearing for the Case

Andrew G. Paradis and E. Martin Davidoff , for petitioner.

Brian J. Bilheimer , for respondent.

MEMORANDUM OPINION

In these consolidated cases petitioner seeks review pursuant to sections 6320(c) and 6330(d)(1) of the determinations by the Internal Revenue Service (IRS) to uphold the filings of two notices of Federal tax lien (NFTL) and two notices of intent to levy.1 In each of these...

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