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PIPER TRUCKING & LEASING, LLC v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 20468-21L.

161 T.C. No. 3

PIPER TRUCKING & LEASING, LLC, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 14, 2023.

Attorney(s) appearing for the Case

Steven Piper (an officer), for petitioner.

Kathryn E. Kelly and Justin E. Wayne , for respondent.

OPINION

This matter is before the Court pursuant to Rule 121 on petitioner's Motion for Summary Judgment and respondent's Motion for Summary Judgment.1 The primary issue for decision is whether a section 6721(e) penalty, assessed through respondent's Combined Annual Wage Reporting (CAWR) computer...

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