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MATHIA v. COMMISSIONER OF INTERNAL REVENUE

No. 16483-05L.

T.C. Memo. 2009-120

JEAN MATHIA AND ESTATE OF DOYLE V. MATHIA, DECEASED, JEAN MATHIA, PERSONAL REPRESENTATIVE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 27, 2009.

Attorney(s) appearing for the Case

Mark W. Curnutte, for petitioners.

Ann L. Darnold, for respondent.

MEMORANDUM OPINION

MARVEL, Judge.

Pursuant to section 6330(d),1 petitioners seek review of respondent's determination to proceed with the collection of petitioners' 1982, 1983, and 1984 Federal income tax liabilities. Petitioners also seek review under section 6404(h) of respondent's determination to deny petitioners' request for abatement of interest under section 6404(e).

Background

The parties submitted this...

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