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GODDARD v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 22334-17L, 23743-18L.

T.C. Memo. 2022-96

WILLIAM GODDARD, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, LEE, GODDARD, & DUFFY, LLP, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 19, 2022.

Attorney(s) appearing for the Case

Steven R. Mather , for petitioners.

Heather K. McCluskey and Emerald Smith , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

Petitioners, William Goddard and the law firm Lee, Goddard, & Duffy, LLP (LGD),1 are before the Court contesting the Internal Revenue Service's (IRS's) determinations in their respective collection due process (CDP) hearings.2

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