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KAYE v. COMMISSIONER

Docket No. 7069-02L.

85 T.C.M. 1017 (2003)

T.C. Memo. 2003-74

Stan D. Kaye v. Commissioner.

United States Tax Court.

Filed March 13, 2003.

Attorney(s) appearing for the Case

Stan D. Kaye, pro se.

Hieu C. Nguyen, for the respondent.

MEMORANDUM OPINION

GERBER, Judge:

Respondent, in a motion filed on November 12, 2002, moved for summary judgment on the questions of whether he may proceed with collection and whether a section 66731 penalty should be imposed against petitioner. Respondent alleges that all section 6330 prerequisites have been met and that he should be allowed to proceed with collection of petitioner's assessed and outstanding tax liability. With...

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