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CONWAY v. COMMISSIONER

Docket Nos. 23833-08L, 24600-08L.

137 T.C. 209 (2011)

MICHAEL J. CONWAY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. RAYMOND T. NAKANO, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed December 19, 2011.

Attorney(s) appearing for the Case

Tim A. Tarter, for petitioners.

Chris J. Sheldon, for respondent.

OPINION

PARIS, Judge:

Petitioner Michael J. Conway (Conway) and petitioner Raymond T. Nakano (Nakano) petitioned the Court to challenge the Internal Revenue Service Office of Appeals' (IRS Appeals) determinations to sustain: (1) The filing of a notice of Federal tax lien (NFTL) against Conway and (2) a proposed levy against Nakano. See secs. 6321, 6330(c)(3), 6331(a).1 Respondent...

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