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INV. RESEARCH ASSOCIATES, INC. v. COMMISSIONER

Docket No. 16410-05L.

126 T.C. 183 (2006)

126 T.C. No. 7

INVESTMENT RESEARCH ASSOCIATES, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 18, 2006.

Attorney(s) appearing for the Case

Robert E. McKenzie and Kathleen M. Lach, for petitioner.

Sean Robert Gannon and Kathleen C. Schlenzig, for respondent.

OPINION

HAINES, Judge:

The question presented in this collection review case is whether the Court has jurisdiction under sections 6320 and 6330 to review the Decision Letter Concerning Equivalent Hearing (decision letter) upon which the petition for lien or levy action is based.1 As discussed in detail below, we conclude that petitioner failed to timely request an administrative hearing, and, therefore, the decision letter...

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