OPINION
O'TOOLE, District Judge.
The appellant, Taramark Title Company, Inc., filed this appeal pursuant to 26 U.S.C. § 6330(d)(1) to obtain review of an Internal Revenue Service ("IRS") collection determination. After consideration of the parties' oral arguments and written submissions and the administrative record, I conclude that the IRS determination ought to be affirmed.
I.
Taramark, a Massachusetts...
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