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TOLOTTI, JR. v. COMMISSIONER

Docket No. 3011-01L.

83 T.C.M. 1436 (2002)

T.C. Memo. 2002-86

Emil P. Tolotti, Jr. v. Commissioner.

United States Tax Court.

Filed April 1, 2002.

Attorney(s) appearing for the Case

Emil P. Tolotti, Jr., pro se.

Sheara L. Gelman, for the respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge.

This matter is before the Court on respondent's Motion for Summary Judgment, as supplemented, filed pursuant to Rule 121(a).1 Respondent contends that there is no dispute as to any material fact with respect to this collection review matter and that respondent's determination (that the filing of the Notice of Federal Tax Lien for liabilities...

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