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collect a liability for accrued interest on petitioners’ tax
liabilities for 1971.
The issues to be decided are as follows:
1. Whether respondent’s issuance of a notice of levy on an
account receivable due petitioners from a customer satisfied
petitioners’ original tax liability for 1971 that was assessed in
1977 because respondent exercised “dominion and control” over the
account receivable;
2. whether we have jurisdiction over petitioners’ 1970 and
1972 tax years;
3. whether res judicata applies to the instant case;
4. whether collateral estoppel applies to the instant case;
5. whether the bankruptcy trustee of petitioners’ customer
is personally liable to respondent under 31 U.S.C. secs. 191 and
192 (2000) and sections 6331 and 6332 for wrongfully refusing to
surrender the customer’s property to respondent; and
6. whether petitioners are entitled to an abatement of
interest accruing for their 1971 tax year pursuant to section
6404.
Background
The parties submitted the instant case fully stipulated,
without trial, pursuant to Rule 122. The parties’ stipulations
of fact are hereby incorporated by this reference and are found
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