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OUR COUNTRY HOME ENTERPRISES, INC. v. C.I.R.

No. 16-1279.

855 F.3d 773 (2017)

OUR COUNTRY HOME ENTERPRISES, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided May 3, 2017.

Attorney(s) appearing for the Case

Alvah Lavar Taylor , Jonathan T. Amitrano , Attorneys, Santa Ana, CA, William J. Wise , Attorney, Wise & Stracks, Chicago, IL, for Petitioner-Appellant.

Michael J. Haungs , Gilbert Steven Rothenberg , Jennifer M. Rubin , Attorneys, Department of Justice, Washington, DC, for Respondent-Appellee.

Before Bauer and Kanne, Circuit Judges, and Feinerman, District Judge.

This case presents an issue of first impression in our circuit — one that requires us to delve into the abstruse world of federal-tax procedure. In this appeal, we address whether Our Country Home Enterprises, Inc. may challenge its liability for a tax penalty in a Collection Due Process ("CDP") hearing after having...

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