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CHAPMAN GLEN LTD. v. COMMISSIONER

Docket Nos. 29527-07L, 27479-09.

140 T.C. 294 (2013)

140 T.C. No. 15

CHAPMAN GLEN LIMITED, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 28, 2013.

Attorney(s) appearing for the Case

Vicken Abajian and Gary Michael Slavett , for petitioner.

Najah J. Shariff , James C. Hughes , and Michael K. Park , for respondent.

WHERRY, Judge:

These cases are consolidated for purposes of trial, briefing, and opinion. Petitioner petitioned the Court in docket No. 29527-07L to review the Internal Revenue Service (IRS) Office of Appeals' determination sustaining respondent's proposed levy on petitioner's property to collect $66,539 in additions to tax for 2004. The additions to tax relate to respondent's determination that petitioner failed to timely file Forms 990, Return of Organization...

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