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ATL & SONS HOLDINGS, INC. v. COMMISSIONER

Docket No. 16288-16L.

152 T.C. 138 (2019)

152 T.C. No. 8

ATL & SONS HOLDINGS, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 13, 2019.

Attorney(s) appearing for the Case

Ralph T. Allen, Jr. (an officer), for petitioner.

Rachel L. Gregory and Bartholomew Cirenza , for respondent.

OPINION

In this collection due process ("CDP") case, petitioner ATL & Sons Holdings, Inc. ("ATL"), seeks review pursuant to section 6330(d)(1)1 of the determination by the Office of Appeals ("Appeals") of the Internal Revenue Service ("IRS") to...

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