MEMORANDUM FINDINGS OF FACT AND OPINION
PANUTHOS, Chief Special Trial Judge.
This case is before the Court on petitioner's request for judicial review of an Internal Revenue Service (IRS) determination to sustain a notice of intent to levy to collect assessed backup withholding taxes and additions to tax.
Pursuant to two Forms 2504-AD, Excise or Employment Tax— Offer of Agreement to Assessment and Collection of Additional Tax and Offer of...
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