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ROGER D. v. COMMISSIONER

Dkt. No. 11319-05L.

93 T.C.M. 946 (2007)

T.C. Memo. 2007-47

Roger D. and Mary M. Catlow v. Commissioner.

United States Tax Court.

March 1, 2007.

Attorney(s) appearing for the Case

Terri A. Merriam, Jennifer A. Gellner, Jaret R. Coles, and Asher B. Bearman, for petitioners.

Thomas N. Tomashek and Gregory M. Hahn, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Petitioners petitioned the Court under section 6330(d) to review the determination of respondent's Office of Appeals (Appeals) sustaining a proposed levy relating to $541,620 of Federal income taxes (inclusive of additions to tax, penalties, and interest) owed by petitioners for 1981 through 1991.2 Petitioners argue that Appeals was required to accept their offer of $35,000...

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