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MOOSALLY v. COMMISSIONER

Docket No. 6539-12L.

142 T.C. 183 (2014)

PATRICIA A. MOOSALLY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 27, 2014.

Attorney(s) appearing for the Case

Michael E. Breslin , for petitioner.

Marissa J. Savit , for respondent.

Petitioner seeks review, pursuant to section 6320, of respondent's determination to proceed with collection of petitioner's unpaid trust fund recovery penalty liabilities for periods ending March 31 and September 30, 2000, and also petitioner's Federal income tax liability for her 2008 tax year.1 The issues...

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