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HOYLE v. COMMISSIONER

Docket No. 7217-04L.

136 T.C. 463 (2011)

MARTIN DAVID HOYLE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 23, 2011.

Attorney(s) appearing for the Case

Martin David Hoyle , pro se.

Beth A. Nunnink , for respondent.

SUPPLEMENTAL OPINION

WELLS, Judge:

The instant case is before the Court on respondent's motion in limine and petitioner's motion to dismiss respondent's lien.1 We must decide: (1) Whether the proposed Supplemental Stipulation of Facts and exhibits should be admitted into evidence; and (2) whether respondent may refile a notice of Federal tax lien (NFTL) during the pendency of...

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