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CARLSON v. U.S.

No. CIV.A.05-10227-WGY.

394 F.Supp.2d 321 (2005)

Suzanne CARLSON, Appellant v. UNITED STATES of America Appellee.

United States District Court, D. Massachusetts.

October 6, 2005.

Attorney(s) appearing for the Case

Timothy J. Burke, Melissa L. Halbig, Burke & Associates, Braintree, MA, for Suzanne Carlson, Plaintiff.

Barry E. Reiferson, U.S. Department of Justice, Washington, DC, for United States of America, Defendant.

MEMORANDUM AND ORDER

YOUNG, Chief Judge.

I. INTRODUCTION

This case arises out of Suzanne Carlson's appeal under 26 U.S.C. §§ 6320(c) and 6330(d)(1), which allow taxpayers to appeal to a United States District Court determinations by the Internal Revenue Service as to the appropriateness of actions to collect unpaid taxes.

A. Procedural Posture

On February 4, 2005, Suzanne Carlson filed a...

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