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Corporation and Subsidiaries v. Commissioner, T.C. Memo. 1997-
339, that respondent's collection efforts regarding petitioner's
assessed and unpaid tax liability for 1993 are not improper, it
follows that petitioner's Motions to Enforce Refund of an
Overpayment should likewise be denied.
To reflect the foregoing,
Orders denying petitioner's
Motions to Enforce Refund of an
Overpayment will be entered.
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Last modified: May 25, 2011