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ESTATE OF ATKINSON v. COMMISSIONER

Dkt. No. 2865-05L.

93 T.C.M. 1108 (2007)

T.C. Memo. 2007-89

Estate of Melvine B. Atkinson, Deceased, Christopher J. MacQuarrie, Personal Representative v. Commissioner.

United States Tax Court.

April 18, 2007.

Attorney(s) appearing for the Case

Mitchell I. Horowitz, for petitioner.

Stephen R. Takeuchi, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge.

This case is before the Court on a petition for judicial review of a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330.1 The issue for decision is whether respondent abused his discretion in sustaining the proposed levy action for the Estate of Melvine B. Atkinson's (the estate) Federal estate tax liabilities.

FINDINGS OF FACT...

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