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SERNA v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 13202-19L.

T.C. Memo. 2022-66

ALEJANDRO SERNA, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent,

United States Tax Court.

Filed June 27, 2022.

Attorney(s) appearing for the Case

Eugene Thomas Ryder , for petitioner.

Stanislaw Balazia , for respondent.

MEMORANDUM OPINION

In this collection due process (CDP) case petitioner Alejandro Serna seeks review pursuant to sections 63201 and 6330 of a determination by the Internal Revenue Service (IRS) Office of Appeals2 upholding the filing of a notice of federal tax lien...

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