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CHILD ADULT INTERVENTION SERVICES, INC. v. COMMISSIONER OF INTERNAL REVENUE

No. 14518-10L.

T.C. Memo. 2012-94

CHILD ADULT INTERVENTION SERVICES, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed March 28, 2012.

Attorney(s) appearing for the Case

Richard B. King (an officer), for petitioner.

Michael W. Lloyd , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

THORNTON, Judge.

Pursuant to section 6330(d), petitioner appeals respondent's determination to proceed by levy to collect late-filing penalties pursuant to section 6652(c)(1)(A) for tax years 2005 and 2007.1

FINDINGS OF FACT

The parties have stipulated some facts, which we incorporate by this reference. When the petition was filed, petitioner was a corporation created...

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