T.C. Memo. 2007-93 UNITED STATES TAX COURT INDUSTRIAL INVESTORS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14928-04L. Filed April 23, 2007. William G. Wells, for petitioner. Elaine T. Fuller, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION HOLMES, Judge: The Commissioner sent Industrial Investors, Inc., a notice saying that he intended to levy on its property to collect unpaid 1990, 1991, and 1992 taxes. Industrial asked for a collection due process (CDP) hearing. Though Industrial is located near Los Angeles, the revenue officer handling the case forwarded Industrial’s files, along with a cover letterPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007