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INDUSTRIAL INVESTORS v. COMMISSIONER

Dkt. No. 14928-04L.

93 T.C.M. 1126 (2007)

T.C. Memo. 2007-93

Industrial Investors v. Commissioner.

United States Tax Court.

April 23, 2007.

Attorney(s) appearing for the Case

William G. Wells, for petitioner.

Elaine T. Fuller, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HOLMES, Judge:

The Commissioner sent Industrial Investors, Inc., a notice saying that he intended to levy on its property to collect unpaid 1990, 1991, and 1992 taxes. Industrial asked for a collection due process (CDP) hearing. Though Industrial is located near Los Angeles, the revenue officer handling the case forwarded Industrial's files, along with a cover letter describing in some detail why she thought the levy...

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