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Dana Street in Taunton, Massachusetts. On September 29, 1994,
respondent issued petitioners a notice of seizure for real estate
located on Beach Street in Wareham, Massachusetts.
On September 26, 1994, the U.S. District Court for the
District of Massachusetts dismissed petitioners’ claims in Civil
Action No. 90-10178-WAG by granting the Government’s motion to
dismiss for failure to state a claim on which relief can be
granted and, alternatively, motion for summary judgment for
petitioners’ failure to present sufficient evidence for actual
direct economic damages.
On October 4, 1994, respondent sent petitioners a notice of
release of levy relating to six parcels of land on Dana Street in
Taunton, Massachusetts, and one parcel of land on Beach Street in
Wareham, Massachusetts.
On December 1, 1999, the U.S. Bankruptcy Court for the
Middle District of Pennsylvania issued an order for final
distribution for MMI’s bankruptcy estate.
On February 7, 2000, respondent issued petitioners a Final
Notice--Notice of Intent to Levy and Notice of Your Right to A
Hearing for petitioners’ 1971 tax year, which indicated that
petitioners owed $34,382.77 of the original liability and
$447,022.46 in interest for a total liability of $481,405.23.
On March 2, 2000, petitioners sent respondent a request for
a section 6330 hearing. In their section 6330 hearing request,
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