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Legal Opinion

Gary M. Dennis & Sharon D. Dennis v. Commissioner

United States Tax Court

Decided July 1, 2020No. 398-18LUnpublished

1Opinion of the Court

T.C. Memo. 2020-98

UNITED STATES TAX COURT GARY M. DENNIS AND SHARON D. DENNIS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 398-18L. Filed July 1, 2020. A collection due process (CDP) hearing pursuant to I.R.C. secs. 6320 and 6330 was held with respect to (1) a notice of Federal tax lien filing for 2013 and 2014 and (2) a notice of intent to levy for 2014. R issued notices of determination that (1) sustained the filing of the notice of Federal tax lien for 2013 and 2014 and (2) did not sustain the levy for 2014. Ps, who are self-represented, filed a timely petition.…

2Cases cited6 opinions

  1. Minahan v. CommissionerUnited States Tax Court · 1987
  2. Landry v. CommissionerUnited States Tax Court · 2001
  3. Frisch v. CommissionerUnited States Tax Court · 1986
  4. Dalton, Jr. v. Commissioner of IRSCourt of Appeals for the First Circuit · 2012
  5. Dunaway v. Comm'rUnited States Tax Court · 2005

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