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BLUE LAKE RANCHERIA ECON. DEV. CORP. v. COMM'R

Docket Nos. 16150-17L, 16189-17L.

152 T.C. 90 (2019)

152 T.C. No. 5

BLUE LAKE RANCHERIA ECONOMIC DEVELOPMENT CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. MAINSTAY BUSINESS SOLUTIONS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 6, 2019.

Attorney(s) appearing for the Case

Robert R. Rubin , Jonathan Edward Strouse , and Michael E. Chase , for petitioners.

Mark Alexander Ericson and Mark L. Hulse , for respondent.

In these consolidated collection due process (CDP) cases, petitioners seek review pursuant to section 6330, as made applicable by section 6320(c), of respondent's determinations set forth in his notices of determination.1 Respondent initiated the collection actions with respect to

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