No. CIV.A.03-12011-GAO.

402 F.Supp.2d 323 (2005)

TARAMARK TITLE COMPANY, INC., Appellant v. UNITED STATES of America, Appellee.

United States District Court, D. Massachusetts.

September 30, 2005.

Attorney(s) appearing for the Case

Timothy J. Burke, Burke & Associates, Braintree, MA, for Appellant.

Barry E. Reiferson, U.S. Department of Justice, Washington, DC, for Appellee.


O'TOOLE, District Judge.

The appellant, Taramark Title Company, Inc., filed this appeal pursuant to 26 U.S.C. § 6330(d)(1) to obtain review of an Internal Revenue Service ("IRS") collection determination. After consideration of the parties' oral arguments and written submissions and the administrative record, I conclude that the IRS determination ought to be affirmed.

I. Background

Taramark, a Massachusetts...

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