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CRIM v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 16574-17L.

T.C. Memo. 2021-117

JOHN M. CRIM, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed October 4, 2021.

Attorney(s) appearing for the Case

Joseph A. DiRuzzo III and Daniel M. Lader , for petitioner.

Ryan Z. Sarazin and Bartholomew Cirenza , for respondent.

MEMORANDUM OPINION

In this collection due process (CDP) case petitioner seeks review pursuant to section 6330(d)(1) of the determination by the Internal Revenue Service (IRS or respondent) to uphold a notice of intent to levy.1 The IRS initiated the levy in an effort to collect penalties assessed...

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