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CARPENTER v. COMMISSIONER

Docket No. 5327-17L.

152 T.C. 202 (2019)

152 T.C. No. 12

RANDY ALAN CARPENTER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 18, 2019.

Attorney(s) appearing for the Case

Randy Alan Carpenter, pro se.

Johnny Craig Young, Abby Moua, and Scott Lyons, for respondent.

OPINION

In this collection due process (CDP) case petitioner seeks review under sections 6320(c) and 6330(d)(1) of the Internal Revenue Service (IRS) Office of Appeals' (Appeals) determination sustaining a Letter 3172, Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 (NFTL), and a Letter 1058,...

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