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RAFIEE v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 8800-21L.

T.C. Memo. 2023-119

FARID RAFIEE AND MISUK P. RAFIEE, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 26, 2023.

Attorney(s) appearing for the Case

Alissa S.L. Gipson and Renesha N. Fountain, for petitioners.

Courtney M. Hill and Gordon P. Sanz, for respondent.

MEMORANDUM OPINION

In this collection due process (CDP) case petitioners seek review pursuant to section 6330(d)(1)1 of the determination by the Internal Revenue Service (IRS or respondent) to uphold the filing of a notice of intent to levy. The notice relates to petitioners' income tax liability...

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