CADE v. COMMISSIONER

Docket No. 7723-23L.

T.C. Memo. 2025-20

WILLIAM J. CADE AND MARY E. CADE, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed March 10, 2025.


Attorney(s) appearing for the Case

David L. Evans, for petitioners.

William J. Winspear and John M. Janusz, for respondent.


MEMORANDUM OPINION

In this collection due process (CDP) case petitioners challenge their underlying tax liability for 2019. They filed a return reporting a liability of $293,822, which they did not fully pay. The Internal Revenue Service (IRS or respondent) commenced collection action, and they sought a CDP hearing under...

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