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DANIEL J. v. COMMISSIONER

Docket No. 10741-01L.

83 T.C.M. 1786 (2002)

T.C. Memo. 2002-141

Daniel J. and Ruth E. Tapio v. Commissioner.

United States Tax Court.

Filed June 4, 2002.

Attorney(s) appearing for the Case

Daniel J. Tapio and Ruth E. Tapio, pro sese.

Randall L. Preheim, for the respondent.

MEMORANDUM OPINION

GERBER, Judge:

This case involves the question of whether respondent, under the provisions of I.R.C. section 6330,1 may proceed with the collection of petitioners' outstanding and unpaid tax liability. On February 5, 2002, respondent moved for summary judgment, and a hearing on that motion was held at the Court's April 29, 2002, Denver, Colorado, trial session. Petitioners argue that as a matter of law respondent...

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