OPINION
COHEN, Judge:
This case was commenced in response to a Notice of Determination Concerning Collection Actions(s) Under Section 6320 and/or 6330 addressed to "Medical Practice Solutions LLC, Carolyn Britton, Sole Member" (petitioner), with respect to unpaid employment taxes for quarters ended March 31 and June 30, 2006. Unless otherwise indicated, all section references are to the Internal Revenue Code and all Rule references are to the Tax Court Rules...
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