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CLAYTON v. COMMISSIONER

Docket No. 17704-05L.

92 T.C.M. 222 (2006)

T.C. Memo. 2006-188

Donald and Yvonne Clayton v. Commissioner.

United States Tax Court.

September 5, 2006.

Attorney(s) appearing for the Case

Terri A. Merriam, Jaret R. Coles, Asher B. Bearman, and Jennifer A. Gellner, for petitioners.

Thomas N. Tomashek and Gregory M. Hahn, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Petitioners petitioned the Court under section 6330(d) to review the determination of respondent's Office of Appeals (Appeals) sustaining a proposed levy relating to $203,798 of Federal income taxes owed by petitioners for 1982 through 1986.1 Petitioners argue that Appeals was required to accept their offer of $100,000 to compromise what they estimate is their approximately...

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