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KESTIN v. COMMISSIONER

Docket No. 18254-17L.

153 T.C. 14 (2019)

GWENDOLYN L. KESTIN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed August 29, 2019.

Attorney(s) appearing for the Case

Gwendolyn L. Kestin, for herself.

Tammie A. Geier and J. Craig Young, for respondent.

The Office of Appeals ("Appeals") of the Internal Revenue Service ("IRS") issued to petitioner Gwendolyn L. Kestin, on July 31, 2017, a "Notice of Determination ["NOD"] Concerning Collection Action(s) Under Section 6320 and/or 6330 of the Internal Revenue Code" pursuant to sections 6320(c) and 6330(c)(3).1

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