Alexander Strashny & Laura Strashny v. Commissioner

T.C. Memo. 2020-82

UNITED STATES TAX COURT ALEXANDER STRASHNY AND LAURA STRASHNY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13836-19L. Filed June 11, 2020. Jeremy M. Vaida and Michael Y. Goldberg, for petitioners. Ryan Z. Sarazin, for respondent. MEMORANDUM OPINION LAUBER, Judge: In this collection due process (CDP) case, petitioners seek review pursuant to section 6330(d)(1)1 of a determination by the Internal 1 All statutory references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice…