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suggest, any reason why respondent’s proposed levy with respect
to their 1994 and 1996 tax years should not proceed.5
In light of the foregoing,
Decision will be entered
for respondent with respect to
petitioners’ 1994 and 1996 tax
years and for petitioners with
respect to petitioners’ 1997 tax
year.
5 At trial, respondent’s counsel suggested that as a result
of moving petitioners’ $611 payment from 1994 to 1997,
petitioners’ 1994 balance would increase accordingly. We note,
however, that respondent’s proposed levy with respect to
petitioners’ 1994 taxes does not presently encompass any
liabilities resulting from reversal of the $611 credit to
petitioners’ 1994 account.
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Last modified: May 25, 2011