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GROSS v. COMMISSIONER OF INTERNAL REVENUE

No. 26902-07L.

T.C. Memo. 2010-176

STUART A. GROSS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed August 5, 2010.

Attorney(s) appearing for the Case

Steven Mather and Elliott Kajan, for petitioner.* Elaine Fuller, for respondent.

MEMORANDUM OPINION

VASQUEZ, Judge.

Pursuant to section 6330(d),1 petitioner seeks judicial review of respondent's determination to proceed with a proposed levy to collect petitioner's unpaid Federal income tax liabilities for 1998, 1999, 2000, and 2001. The matter is presently before the Court on petitioner's motion for summary judgment and respondent's motion for partial summary judgment pursuant to Rule 121. We are asked to...

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