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LOUIS S. v. COMMISSIONER

Docket No. 13244-01L.

83 T.C.M. 1893 (2002)

T.C. Memo. 2002-159

Louis S. and Laura L. Schnitzler v. Commissioner.

United States Tax Court.

Filed June 24, 2002.

Attorney(s) appearing for the Case

Louis S. and Laura L. Schnitzler, pro sese.

Laurence K. Williams and Thomas R. Mackinson, for the respondent.

MEMORANDUM OPINION

PANUTHOS, Chief Special Trial Judge:

This matter is before the Court on respondent's motion for summary judgment, as supplemented, 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 1996 and 1997 should be sustained as...

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