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COLEMAN III v. COMMISSIONER

Docket No. 5995-01L.

83 T.C.M. 1748 (2002)

T.C. Memo. 2002-132

Shade D. Coleman III and Maria M. Coleman v. Commissioner.

United States Tax Court.

Filed May 30, 2002.

Attorney(s) appearing for the Case

Shade D. Coleman III and Maria M. Coleman, pro sese.

Karen Baker and Rollin G. Thorley, for the respondent.

MEMORANDUM OPINION

PANUTHOS, Chief Special Trial Judge:

This matter is before the Court on respondent's motion for summary judgment pursuant to Rule 121.1 Respondent contends that there is no dispute as to any material fact with respect to this levy action, and that respondent's determination to proceed with collection of petitioners' outstanding tax liabilities for 1997 should be sustained as a matter of law.

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