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MARTIN v. COMMISSIONER

Dkt. No. 3876-05L.

93 T.C.M. 1047 (2007)

T.C. Memo. 2007-73

Martin and Sharon Smith v. Commissioner.

United States Tax Court.

March 29, 2007.

Attorney(s) appearing for the Case

Wendy S. Pearson, Terri A. Merriam, Jennifer A. Gellner, Jaret R. Coles, and Asher B. Bearman, for petitioners.1

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

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Petitioners Martin Smith (Smith) and Sharon Smith petitioned the Court under section 6330(d) to review the determination of respondent's Office of Appeals (Appeals) sustaining a proposed levy related to petitioners' assessed Federal income tax liability (inclusive of additions to tax, penalties, and interest) for 1984, 1985, 1986, and 1991; that liability totaled $79,461. Petitioners argue that the proposed...

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