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WYLIE v. COMMISSIONER

Docket No. 6949-00L.

81 T.C.M. 1368 (2001)

T.C. Memo. 2001-65

Alan R. Wylie v. Commissioner.

United States Tax Court.

Filed March 20, 2001.

Attorney(s) appearing for the Case

Thomas W. Roberts, for the petitioner.

Karen Nicholson Sommers, for the respondent.

MEMORANDUM OPINION

LARO, Judge.

This case is based on a petition filed under section 6330(d).1 Respondent moved for summary judgment under Rule 121(a) on November 6, 2000. The Court, by order dated November 8, 2000, required petitioner to respond to respondent's motion by November 29, 2000. Petitioner did not file a response. For convenience, we shall combine the facts, which are not in dispute, with our opinion.

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