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GIAMELLI v. COMMISSIONER

Docket No. 23150-04L.

129 T.C. 107 (2007)

129 T.C. No. 14

JOSEPH GIAMELLI, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 30, 2007.

Attorney(s) appearing for the Case

Erasmo S. Bruno, for petitioner.

Marc L. Caine, for respondent.

OPINION

GOEKE, Judge:

This case is before the Court for review of a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination).1 Respondent has moved to dismiss for lack of prosecution on the grounds that no party has been substituted for Joseph Giamelli since his death. Alternatively, respondent has moved for summary judgment...

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