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DAVID v. COMMISSIONER

Docket No. 4671-01L.

83 T.C.M. 1781 (2002)

T.C. Memo. 2002-140

David and Theresa Smeton v. Commissioner.

United States Tax Court.

Filed June 3, 2002.

Attorney(s) appearing for the Case

David and Theresa Smeton, pro sese.

Wendy S. Harris and 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 And To Impose A Penalty Under I.R.C. Section 6673, filed 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...

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