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ROSENTHAL v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 28214-12L.

T.C. Memo. 2014-252

JAY ROSENTHAL, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed December 15, 2014.

Attorney(s) appearing for the Case

Steven Ray Mather, for petitioner.

Mindy S. Meigs, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge.

This case arises from a petition for judicial review filed in response to Notices of Determination Concerning Collection Action(s) Under Section 6320 and/or 63301 with respect to petitioner's Federal income tax liabilities for 2001, 2004,2 2006, and 2008. The issue remaining for decision is whether respondent abused his discretion in sustaining...

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