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ALESSIO AZZARI, INC. v. COMMISSIONER

Docket No. 27532-08L.

136 T.C. 178 (2011)

ALESSIO AZZARI, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 24, 2011.

Attorney(s) appearing for the Case

Barry A. Furman , for petitioner.

James H. Harris, Jr. , for respondent.

OPINION

WELLS, Judge:

This case is before the Court on respondent's motion for summary judgment and petitioner's cross-motion for summary judgment pursuant to Rule 121.1 We must decide whether respondent's settlement officer abused his discretion in denying petitioner's request to subordinate or withdraw a notice of Federal tax lien (NFTL), or in denying petitioner's request for an installment agreement.

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