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BALTIC v. COMMISSIONER

Docket No. 2826-06L.

129 T.C. 178 (2007)

129 T.C. No. 19

PETER P. BALTIC AND KAREN R. BALTIC, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 27, 2007.

Attorney(s) appearing for the Case

Joe Alfred Izen, Jr., for petitioners.

Wesley J. Wong, for respondent.

OPINION

HOLMES, Judge:

The Code encourages taxpayers to settle their differences with the IRS by compromise rather than litigation. One type of compromise is a compromise based on doubt as to liability, and that's the kind that Peter and Karen Baltic offered to the IRS. But they made their offer just as the IRS was poised to begin seizing their property—and after they had had a chance to contest their liability in our Court. Section 6330

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