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GUNDERSON v. COMMISSIONER

Docket No. 16050-99L.

83 T.C.M. 1143 (2002)

T.C. Memo. 2002-26

Harley Gunderson v. Commissioner.

United States Tax Court.

Filed January 25, 2002.

Attorney(s) appearing for the Case

Harley Gunderson, pro se.

Marty J. Dama, for the respondent.

MEMORANDUM OPINION

VASQUEZ, Judge:

This case is before the Court on respondent's motion under Rule 120,1 which, pursuant to Rule 120(b), the Court shall treat as respondent's motion for summary judgment under Rule 121.

The sole issue is whether respondent's determination to proceed with collection as to petitioner's 1993 taxable year was an abuse of discretion.

Background

At the time the petition...

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