DAF CHARTERS, LLC v. COMMISSIONER

Docket No. 21317-14L.

152 T.C. 250 (2019)

DAF CHARTERS, LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 9, 2019.


Attorney(s) appearing for the Case

Glen A. Stankee , for petitioner.

Brandon S. Cline and Kenneth A. Hochman , for respondent.


OPINION

This collection due process (CDP) case brought under section 6330(d)(1)1 is before the Court on cross-motions for summary judgment. As explained below, we will deny summary judgment for petitioner and grant respondent's cross-motion.

Background

The facts set...

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