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CLARK v. COMMISSIONER

Docket No. 3082-05L.

125 T.C. 108 (2005)

125 T.C. No. 7

HERBERT AND ROSALIE CLARK, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 26, 2005.

Attorney(s) appearing for the Case

Jeffrey E. Rattner and Steve Mather, for petitioners.

Elaine T. Fuller, for respondent.

OPINION

LARO, Judge:

Petitioners petitioned the Court under section 6330(d) to review a determination of the Commissioner's Office of Appeals (Appeals) sustaining respondent's levy upon their State tax refund.1 Respondent made the levy to collect additions to tax assessed as to petitioners' 1997 Federal income tax. The sole issue in this Opinion is whether the Court has jurisdiction...

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