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GENE v. COMMISSIONER

Docket No. 5695-01L.

83 T.C.M. 1757 (2002)

T.C. Memo. 2002-135

Gene and Ciao Newman v. Commissioner.

United States Tax Court.

Filed May 30, 2002.

Attorney(s) appearing for the Case

Gene and Ciao Newman, pro sese.

Wendy S. Harris and Karen Lynne Baker, for the respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge.

This matter is before the Court on respondent's Motion For Summary Judgment And To Impose A Penalty Under I.R.C. Section 6673, as supplemented.1 Respondent contends that there is no dispute as to any material fact with respect to this lien and levy action and that respondent's determination to proceed with collection of petitioners' outstanding tax liabilities for the taxable years...

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