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HINERFELD v. COMMISSIONER

Docket No. 20946-08L.

139 T.C. 277 (2012)

NORMAN HINERFELD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 27, 2012.

Attorney(s) appearing for the Case

Richard Stephen Kestenbaum , for petitioner.

Donald Alan Glasel , for respondent.

GALE, Judge:

Pursuant to section 6330(d),1 Norman Hinerfeld (petitioner) seeks review of respondent's determination to proceed with a levy to collect petitioner's unpaid trust fund recovery penalties (trust fund penalties), assessed pursuant to section 6672, for the quarterly periods ended September 30 and December 31, 2002, March 31, September 30, and December 31, 2003, and June 30, 2004. The issues for decision are: (1) whether...

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