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BRANDON v. COMMISSIONER OF INTERNAL REVENUE

No. 7837-07L.

133 T.C. No. 4

ESTATE OF MARK BRANDON, DECEASED, JANET BRANDON, EXECUTRIX, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed August 27, 2009.

Attorney(s) appearing for the Case

N. Dean Hawkins, for petitioner.

Adam Flick, for respondent.

OPINION

FOLEY, Judge.

The issue for decision is whether there was an abuse of discretion in sustaining a notice of Federal tax lien (NFTL) relating to 2003 trust fund recovery penalties (trust penalties) assessed against Mark Brandon (Mr. Brandon). The parties submitted this case fully stipulated pursuant to Rule 122.1

Background

On August 9, 2004, respondent issued Mr. Brandon a proposed assessment regarding...

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