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The only issue you may be able to raise in US Tax Court is whether or not the IRS was right to proceed with the seizures and the levies. The IRS only needs to prove that they gave you an opportunity to have hearings and propose other collection options. Generally, the IRS usually wins on this issue. Given the fact that the levies have already happened, you may have already passed all the applicable Tax Court filing deadlines. You should talk to a local tax attorney about the specifics of your case to determine if filing a US Tax Court petition would be advisable.
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